- 6 - 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 wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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