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At the time that the petition was filed, petitioner was in
the custody of the U.S. Bureau of Prisons and was incarcerated in
Illinois, the State in which he resided immediately prior to his
incarceration.
A. Petitioner’s Education and Occupation
Petitioner graduated from college with a degree in
accounting. Thereafter, from 1967 to 1970, petitioner attended
law school. After earning his degree, petitioner was admitted to
the Illinois State bar and entered the private practice of law.
During 1989, 1990, and 1991, the taxable years in issue,
petitioner was self-employed as an attorney and maintained a law
office in Peoria, Illinois. Petitioner’s practice included
litigation.
B. Petitioner’s 1989 Income Tax Return
Petitioner filed Form 1040, U.S. Individual Income Tax
Return, for 1989, listing his occupation as “lawyer”. Petitioner
attached to his return Schedule C, Profit or Loss From Business,
and reported thereon income and expenses from his law practice.
None of the deductions claimed on Schedule C included any
deduction for the loss of, or damage to, business property.
On page 2 of his Form 1040, petitioner claimed the standard
deduction. Nevertheless, petitioner attached Schedule A,
Itemized Deductions, to his return. On Schedule A, petitioner
claimed deductions for State and local income taxes and
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