- 5 - (5) he needed to attend a closing, (6) he needed to attend a closing for a friend, (7) he needed to attend a closing for his law firm, (8) the weather was too bad, (9) he was working on a political campaign, (10) he had to be in court, (11) he was too busy with his law practice, and (12) he was stung by a wasp. Because of petitioner’s excuses to reschedule the substantiation conferences, this matter languished for more than 2 years in Exams. After 2-1/2 years of futile attempts at rescheduling substantiation conferences with petitioners, respondent issued a statutory notice of deficiency (Notice) on September 6, 2001. In the Notice, respondent disallowed $67,906 claimed by petitioners on Schedule C-15 as ordinary and necessary expenses incurred in operating petitioner’s law practice, $22,828 claimed by petitioners on Schedule C-26 as ordinary and necessary expenses incurred in serving as a divorce referee, and $7,541 claimed in Schedule E rental losses.7 Respondent also assessed an accuracy- 5 Regarding petitioner’s law practice, petitioner failed to provide documentation to substantiate car expenses, utilities, phone, travel expenses, taxes and licenses, contract labor, dues and publications, office expenses, legal and professional services, insurance, and filing fees. 6 Regarding petitioner’s divorce referee services, petitioner failed to substantiate car expenses, contract labor, insurance, interest, office expenses, and travel expenses. 7 Respondent also increased petitioners’ Schedule C gross receipts by $88,587. Respondent subsequently conceded, however, (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011