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WELLS, Judge: This case was assigned to Special Trial Judge
Robert N. Armen, Jr., pursuant to Rules 180, 181, and 182.1 The
Court agrees with and adopts the Opinion of the Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax for the taxable
year 1993 in the amount of $1,260. After concessions by
petitioners,2 the issue for decision is whether petitioners are
entitled to deduct the entire cost of nonpracticing malpractice
insurance paid during the year in issue. We hold that they are.
FINDINGS OF FACT
This case was submitted fully stipulated under Rule 122, and
the facts stipulated are so found. Petitioners resided in Des
Moines, Iowa, at the time that their petition was filed with the
Court.
Petitioner husband (petitioner) is a lawyer. During the
year in issue, he practiced as a self-employed attorney and
reported his income for the year on a Schedule C.
1 All Rule references are to the Tax Court Rules of
Practice and Procedure, and all section references are to the
Internal Revenue Code in effect for the taxable year in issue.
2 Petitioners concede: (1) They failed to report interest
income in the amount of $207, and (2) respondent properly reduced
petitioner husband's Schedule C deduction by the amount of
$1,447.
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