Nicholas M. Romer - Page 2

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               Respondent determined a deficiency in petitioner's Federal             
          income tax for 1993 in the amount of $5,398.                                
               The issues for decision are:  (1) Whether petitioner is                
          entitled to exclude from gross income certain per diem payments             
          which he received during 1993; (2) whether petitioner's horse               
          selling and leasing activity was an activity not engaged in for             
          profit within the meaning of section 183; (3) whether certain               
          expenses paid by petitioner in connection with his aviation                 
          activity are deductible as ordinary and necessary business                  
          expenses; and (4) whether petitioner is entitled to Schedule A              
          itemized deductions which exceed his claimed standard deduction.            
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner claimed he resided in                 
          Antioch, Tennessee, on the date the petition was filed in this              
          case.                                                                       
               Petitioner has been a certified public accountant since                
          1972.  He founded an accounting firm in Minneapolis, Minnesota,             
          in 1974 which, sometime prior to 1993, was incorporated under the           
          laws of Minnesota as a professional corporation called Romer &              
          Company, P.C. (Romer).  During 1993, petitioner was an 8-percent            
          shareholder and the president of Romer.  Derf Bistodeau, Romer's            
          vice president, owned the remaining 92 percent of Romer's shares.           

          1(...continued)                                                             
          Practice and Procedure.                                                     




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