Hilary Harry Sax - Page 3

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          Tax Court Rules of Practice and Procedure.                                  
               Respondent determined a deficiency in petitioner’s 1999                
          Federal income tax in the amount of $8,788 and a penalty under              
          section 6662(a) in the amount of $1,755.60.                                 
               Petitioner conceded that he (1) received long-term capital             
          gain income in the amount of $1,154 in 1999, (2) received $11,154           
          from Social Security, (3) received interest income in the amount            
          of $155 in 1999, (4) is liable for an addition to tax for 1999              
          pursuant to section 6651(a)(1) and (5) is liable for a penalty              
          under section 6662(a).  After concessions by petitioner, this               
          Court must decide whether petitioner is entitled to a deduction             
          for expenses from Schedule C, Profit or Loss From Business, in              
          the amount of $28,780.                                                      
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioner resided in Los Angeles, California, at the            
          time he filed his petition.                                                 
               Petitioner is 86 years old, is an attorney, and is currently           
          an active member of the State Bar of California.  Petitioner                
          graduated from Harvard Law School in 1944.  He has been engaged             
          in the practice of law for 60 years.                                        
               In 1999, petitioner was a lawyer operating as a sole                   
          proprietor.  On occasion, he used the Sax-Brook Structural                  
          Building Systems, Inc. (Sax Brook) name for his own purposes.               

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