- 2 - Whether petitioners are entitled to deduct certain legal expenses paid in connection with their daughter’s domestic relations proceedings; (2) whether petitioners are entitled to claim depreciation deductions with respect to a rental residence and, if so, the amount of depreciation to which they are entitled; and (3) whether petitioners are liable for a section 6662(a) penalty with respect to the legal expense issue. I. Legal and Professional Fee Deduction FINDINGS OF FACT2 At all pertinent times, petitioners were married and resided in League City, Texas. Jesse Emmit Rupert (petitioner) retired from his position as a drilling manager for Atlantic Richfield Indonesia, Inc. (Atlantic Richfield), on February 1, 1987. Since his retirement, petitioner has been involved in investing and did a limited amount of engineering consulting during 1991. In 1992, petitioners’ daughter Michelle Ann Steele (Michelle) became involved in a divorce proceeding against her then husband, Tad Edward Wilkinson (Tad). When the proceeding was instituted, Michelle and Tad had a daughter, Ashley, who was about 2 years old. During the period 1992 through 1995, 2 Because of the discrete nature of the facts and legal discussion for each issue, the findings of fact and legal discussion for each issue are separately set forth. The fact finding is being segregated for convenience only, and all findings are applicable throughout the opinion. The parties’ stipulation of facts is incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011