- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011