- 9 - 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 wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011