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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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