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accuracy-related penalty under section 6662(a) and (b)(1) (for
1989 and 1990), and/or the delinquency addition to tax under
section 6651(a)(1) (for each of the years at issue).3
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the first supplemental stipulation
of facts are incorporated herein by this reference.
When the petitions in this case were filed, petitioner
resided in St. Paul, Minnesota. Petitioner was married to Thomas
G. Rowe (Rowe) during the years at issue, but she and Rowe filed
joint returns only for 1988-90. Petitioner’s filing status for
1987 was married filing separate.
I. Petitioner’s Reporting of Income and Expenses From Her Law
Practice (Schedule C)
During the years at issue, and for a number of earlier
years, petitioner maintained a sole proprietorship family law
practice, although she regularly retained other attorneys to
provide services in connection with certain of her cases. Each
of the Federal income tax returns filed by petitioner (1987) and
by petitioner and Rowe jointly (1988-90), included a Schedule C,
Profit or (Loss) From Business or Profession (Sole
3Respondent also made adjustments to petitioner’s Schedule
A, Itemized Deductions, and recomputed petitioner’s self-
employment tax for each of the years at issue. Those adjustments
are derivative of the Schedule C, Profit or (Loss) From Business
or Profession (Sole Proprietorship), adjustments and will be
resolved by our resolution of the latter.
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