- 2 - 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 herPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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