- 19 - identified as "William J. Fleischaker, M.D." for which the principal business was the provision of medical services. The other business was identified as "Deborah Fleischaker, et. al" for which the principal business was oil and gas production. On the Schedules C for oil and gas production activity, petitioners claimed legal and professional expenses of $439,871 for 1991 and $51,950 for 1992. None of the claimed legal and professional expenses were related to the oil and gas production activity. Except for $11,149 of the fees claimed in 1992, the fees claimed as legal and professional fees from oil and gas production were for payments made by petitioner under his guaranty obligations for Adult Living Center debts and legal fees incurred in defending against those obligations. The remaining $11,149 claimed in 1992 was related to petitioner's medical services activity. In the notice of deficiency, respondent disallowed a deduction for all $439,871 of legal fees claimed on the 1991 return and $40,801 of the fees claimed in 1992. Respondent did not disallow the $11,149 of fees claimed as a deduction related to gas and oil production in 1992 that were related to petitioner's medical services activity.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011