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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1992 $3,122 $624
1993 3,138 628
The Court must decide: (1) Whether petitioner is entitled
to deduct Schedule C expenses; (2) whether petitioner is entitled
to additional itemized deductions; (3) whether petitioner is
entitled to deduct rental expenses; and (4) whether petitioner is
liable for the accuracy-related penalties under section 6662(a).
Some of the facts have been stipulated and are so found.
Petitioner resided in New York, New York, when his petition was
filed.
During the taxable years in issue, petitioner was a teacher
for the New York City Board of Education. Petitioner also was an
attorney admitted to practice in the State of Connecticut.
Petitioner's solo law practice was located in Bridgeport,
Connecticut. During 1992 and 1993, petitioner was involved in
the litigation of two civil cases on a contingency-fee basis.
One case involved a medical malpractice claim in which petitioner
claimed his client sought damages, and the case eventually was
settled for $70,000 in 1995. The other case involved a personal
injury claim against the State of Connecticut. The amount of
damages sought was $248,000.
On his Form 1040, U.S. Individual Income Tax Return,
petitioner reported $32,281 in 1992 and $37,030 in 1993, in gross
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Last modified: May 25, 2011