- 6 - D. Petitioner’s Law and Accounting Practice During the years in issue, petitioner worked 2,600 to 2,900 hours per year in his office on his legal and accounting practices. He worked 1,600 to 1,900 of those hours from October to April. He worked many additional hours outside of the office doing legal research and reading professional publications. Petitioner represents clients before the Internal Revenue Service in his law and accounting practices and is familiar with section 183 and its regulations. Petitioner does not have a separate checking account for his law practice. E. Petitioners’ Tax Returns Petitioners reported on Schedules F, Profit or Loss From Farming, attached to their tax returns for 1995, 1996, and 1997, that they operated a livestock/hay farm. Petitioners reported the following amounts of nonfarm income on their income tax returns filed for 1995, 1996, and 1997: Year Wages Schedule C Income Nonfarm Income 1995 $47,450 $12,132 $69,704 1996 50,914 7,745 69,258 1997 54,010 5,908 71,050Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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