Charles and Beatrice M. Reynolds - Page 6




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          B.   Legal Expenses                                                         
               In or about 1988, petitioner obtained permission from the              
          IRS to engage in the limited practice of law.  Petitioner’s law             
          practice was limited by standard employee rules of conduct                  
          promulgated by the IRS.                                                     
               Petitioner’s law practice generated receipts from real                 
          estate closings and related activities.  During 1993, petitioner            
          performed approximately four real estate closings and reported              
          gross receipts of $700.  Petitioner conducted two real estate               
          closings in 1994 and reported gross receipts of $450.                       
               Sometime in 1992, petitioner was “invited” to a meeting with           
          the Inspection Division of the IRS (Inspection).  At the meeting,           
          Inspection told petitioner that he was under investigation for              
          practicing law during the official hours of his employment with             
          the IRS.                                                                    
               Finding himself under investigation by his employer,                   
          petitioner obtained legal counsel.  Legal counsel represented               
          petitioner throughout the investigation.  The investigation did             
          not end until 1995.  Petitioner claimed attorney’s fees on                  
          Schedule C of his joint individual Federal income tax returns of            
          $2,380 in 1993 and $5,615 in 1994 in connection with the                    
          investigation.                                                              
               In 1994 petitioners were considering suing Mrs. Reynolds’              
          employer for sex discrimination.  Lori D. Ecker of Chicago was              





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