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also determined accuracy-related penalties under section 66621 of
$946 and $618 for 1993 and 1994 respectively.
Respondent concedes that petitioners are entitled to deduct
a dependency exemption amount for Mrs. Reynolds’ mother for tax
year 1993 and that petitioners expended at least $6,125 for her
medical expenses in 1993. Respondent also concedes that Charles
Reynolds (petitioner) was engaged in the practice of law with a
profit motive and for 1993 had $140 of deductible expenses for
bar membership fees.
After concessions by respondent, the issues for decision2
are: (1) Whether respondent is estopped from asserting
deficiencies against petitioners; (2) whether respondent has
offered evidence of petitioners’ tax returns for either year at
issue; (3) whether petitioners are entitled to deductions for
medical expenses; (4) whether legal expenses incurred by
petitioners are itemized deductions or trade or business
expenses; (5) whether petitioners are entitled to deduct various
Schedule C expenses; (6) whether petitioners are entitled to
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
2 The amount of petitioners’ self-employment tax, if any, and
their deduction for self-employment tax, if any, will be
determined by our resolution of the issues to be decided in this
case.
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