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South Dakota. His practice in Oregon primarily involved labor
and personal injury law.
In 1986, petitioners moved to Rapid City, South Dakota.
There, petitioner began practicing law as a sole proprietor. To
establish his practice in the Rapid City area, petitioner spent
many hours in the years following the relocation performing pro
bono legal work for the elderly and for Pennington County Legal
Aid, giving talks and seminars and meeting people in the
community. He volunteered in the community to enhance his
reputation. When necessary, petitioner traveled to Oregon to
perform legal services.
Petitioners filed a joint Federal individual income tax
return for each of the years at issue on the following dates:
Year Date Filed
1989 2/01/94
1990 1/10/94
1991 2/15/94
1992 3/30/94
1993 4/15/94
Petitioner included a Schedule C relating to his law practice
with each of the returns. On those Schedules C, petitioner
reported the following gross receipts, total expenses, and net
profit or loss:
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