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Jack H. Kaufman, APC. In a letter dated August 30, 1995,
regarding “COUNSEL OF RECORD STATUS/VARIOUS LITIGATION MATTERS”,
Kaufman wrote to Carter that “you are going to handle all legal
matters on pending cases” and “since you are the owner of JACK H.
KAUFMAN, A.P.C., you have control of all necessary files
pertaining to these and all other client matters.” In a letter
dated August 30, 1995, regarding “COURT DATES AND OTHER COVERAGE
MATTERS/JACK H. KAUFMAN, A.P.C.”, Kaufman listed specific cases
that Carter needed to cover in her “capacity as an employee and
the only attorney for JACK H. KAUFMAN, A.P.C.” Jack H. Kaufman,
APC remained in business throughout 1995.
On its 1995 Form 1120, Jack H. Kaufman, APC claimed a
deduction in the amount of $58,941 for “equipment retired”. The
deduction claimed for “equipment retired” related to client files
and goodwill purportedly owned by Jack H. Kaufman, APC.
Jack H. Kaufman, APC’s corporate income tax return for 1995
was examined by respondent. Respondent initially challenged, and
respondent’s Appeals Office eventually consented to, the claimed
deduction for “equipment retired” by Jack H. Kaufman, APC in
1995.
Notice of Deficiency
On May 8, 2000, respondent issued a notice of deficiency to
petitioner. In the notice of deficiency, respondent determined a
Federal income tax deficiency for petitioner’s tax year ended
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Last modified: May 25, 2011