M. Maureen Polsby - Page 2

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          Procedure.  The Court agrees with and adopts the Opinion of the             
          Special Trial Judge, which is set forth below.                              


                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PAJAK, Special Trial Judge:  Respondent determined a                   
          deficiency in petitioner's 1992 Federal income tax in the amount            
          of $9,345 and an addition to tax under section 6651(a)(1) in the            
          amount of $2,373.                                                           
               The issues for decision are:  (1) Whether petitioner is                
          entitled to Schedule C deductions, (2) whether petitioner is                
          entitled to charitable contribution deductions, and (3) whether             
          petitioner is liable for an addition to tax under section                   
          6651(a)(1) for failure to timely file a return.                             
               Some of the facts have been stipulated and are so found.               
          Petitioner resided in Washington, D.C., at the time the petition            
          was filed.                                                                  
               During 1992, petitioner was a self-employed medical doctor             
          with a specialty in neurology.  Petitioner operated her medical             
          practice in her home office.  Petitioner's home office occupied             
          one-third of her house.  Also during 1992, petitioner reviewed              
          disability claims for the Social Security Administration (SSA) as           
          a consultant.  Petitioner was required to review the disability             
          claims on SSA's premises located in Baltimore, Maryland.  The               
          majority of petitioner's gross income for 1992 resulted from her            





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