- 2 -
The issues for decision are whether petitioner filed Federal
income tax returns for the years in issue; whether respondent
properly determined petitioner’s income from the practice of law;
whether petitioner is entitled to any deductions beyond those
conceded by respondent; and whether petitioner is liable for the
additions to tax determined by respondent. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioner resided in La Mesa, California, when he filed his
petition in this case.
Petitioner was admitted to practice law in California in
June 1976. During 1982 and 1983, petitioner specialized in
immigration law and handled a high volume of amnesty cases,
deportation hearings, asylum applications, and family petitions.
Petitioner’s practice was conducted under the name Santa Ana
Immigration Center (SAIC).
Petitioner maintained bank accounts in the name of SAIC and
held signature authority over the bank accounts.
During 1982, SAIC was operated out of a commercial office
located on North Broadway in Santa Ana, California. In 1983,
SAIC moved to an office on Main Street in Santa Ana.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011