Jack and Janet Freeman - Page 9




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                  Attorney's fees paid               $114,532.39                      
                  to Paul Greenberg, Esq.                                             
                 Less:  reimbursement for                62.69                       
             unused cost advance                                                      
                 Plus:  attorney's fees paid        15,229.00                        
             in 1994 before trial                                                     
             Total additional miscellaneous          129,698.70                       
                  itemized deductions                                                 

                  Respondent also determined that for 1994 petitioners                
             are liable for alternative minimum tax of $52,303.  The                  
             notice of deficiency states as follows:                                  

                  It is determined that you are subject to the                        
                  alternative minimum tax imposed by the Internal                     
                  Revenue Code on items of tax preference for the                     
                  taxable year ended December 31, 1994.  We have                      
                  attached an an [sic] alternative minimum tax                        
                  worksheet to explain how we computed the                            
                  alternative minimum tax.                                            

             Whether the Court Properly Granted Respondent's Motion To                
             Quash Subpoenas To Compel the Testimony of a Revenue Agent               
             and an Appeals Officer                                                   
                  Petitioners ask the Court to reconsider the granting                
             of respondent's motion to quash the subpoenas issued to a                
             revenue agent and to a manager in respondent's Appeals                   
             Office.  According to petitioners' posttrial brief, the                  
             agent would have testified that he advised petitioners'                  
             accountant that petitioners' "return should be accepted as               
             filed", and the Appeals officer would have testified that                
             he informed petitioners' accountant that "the return was                 





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