- 7 -
Ms. Doe. The entire $30,000 was paid by USAA, as well as
petitioner's legal expenses incurred in defending the civil suit.
On that same date, GBC and its insurance companies and other
related entities and employees entered into an out-of-court
settlement with Ms. Doe that called for the payment of $90,000 to
Ms. Doe, the full amount of which was paid by the insurance
companies.
On Schedule C, Profit or Loss From Business (Schedule C), of
his 1991 Federal income tax return, petitioner claimed a
deduction of $13,737 for legal expenses incurred in the defense
of the criminal sexual assault charges. On Schedule C of his
1992 Federal income tax return, petitioner claimed a deduction of
$31,694 for legal expenses incurred in the defense of the
criminal sexual assault charges.
In the notice of deficiency respondent disallowed
petitioner's $13,737 legal expense deduction for 1991 and the
$31,694 legal expense deduction for 1992. Respondent made
several additional adjustments to petitioner's 1992 return that
are not at issue in this case.4
4
For 1992, respondent disallowed $1,749 of petitioner's
claimed $5,000 Schedule C "travel/meals/entertainment" expense
and disallowed petitioner's $3,780 Schedule E "commissions"
expense. Petitioner did not dispute these adjustments, and,
thus, they are considered conceded by petitioner. Rule 34(b)(4);
Jarvis v. Commissioner, 78 T.C. 646, 658 n.19 (1982). Also in
the notice of deficiency, respondent allowed petitioner
additional deductions for Schedule C auto expenses of $2,142,
Schedule C depreciation of $2,083, and Schedule E expenses of
$166.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011