- 2 - year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a deficiency of $15,195 in petitioners’ Federal income taxes for 1997. The deficiency resulted from disallowance of deductions for car and truck expenses, legal and professional expenses, and salaries and wages claimed on Schedule C, Profit or Loss From Business, attached to petitioners’ Federal income tax return. Respondent made adjustments to petitioners’ Schedule A, Itemized Deductions, and determined that petitioners were liable for a 10-percent additional tax on each petitioner’s distribution from a retirement plan. After concessions, the issues remaining for decision are whether petitioners have adequately substantiated expenses subject to section 274(d) or for legal and professional fees claimed and whether the additional tax imposed on early distributions under section 72(t) applies to the distributions received from their retirement plans. Background Petitioner Robert C. Jacobsen (Mr. Jacobsen) was licensed to sell real estate in Arizona and New Jersey prior to and during 1997. Petitioner Carol S. Jacobsen (Mrs. Jacobsen) was employed prior to 1995 as an executive secretary. In 1995, Mrs. Jacobsen was diagnosed with a heart condition, and a heart transplant was recommended. Mrs. Jacobsen had to give up her regular employmentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011