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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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