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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 71,050
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