William Maher - Page 6




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          1996, Mr. Maher worked in the tax department of the New York                
          Times.  When he left the New York Times in 1996, Mr. Maher was              
          its tax director.  From 1997 through September 2001, Mr. Maher              
          performed financial consulting and tax work for Coopers & Lybrand           
          and its successor (Coopers).  In 1998, he was a manager at                  
          Coopers and worked in the Stamford, Connecticut, office.  Since             
          September 2001, Mr. Maher has been a financial consultant and tax           
          return preparer for individuals.                                            
          Mr. Maher’s 1998 Tax Return                                                 
               Mr. Maher received a Form W-2, Wage and Tax Statement, from            
          Coopers for 1998 reporting $121,145 in wages.  He also received             
          Forms 1099-DIV and 1099-INT for 1998 reporting dividends and                
          interest.                                                                   
               Before 1998, Mr. Maher filed all of his required tax                   
          returns.  He did not file a Federal individual income tax return            
          for 1998.  Mr. Maher knew that he was required to file a tax                
          return for 1998 by April 15, 1999.  In 2001, he provided a copy             
          of an unfiled return for 1998 to respondent.                                
                                       OPINION                                        
               Deductions are a matter of legislative grace, and the                  
          taxpayer has the burden of showing that he is entitled to any               
          deduction claimed.3  Rule 142(a); New Colonial Ice Co. v.                   


               3  Mr. Maher does not contend that sec. 7491(a) is                     
          applicable to this case.                                                    





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