- 2 - Respondent determined a deficiency of $3,075 in petitioners’ 1998 Federal income tax and an addition to tax under section 6651(a)(1) of $769.25. After respondent’s concession that petitioners are entitled to an education credit of $383, the issues are whether petitioners are (1) entitled to deduct certain Schedule C, Profit or Loss From Business, business expenses under section 162 relating to a part-time law practice of petitioner Charles A. Brown, Jr. (Mr. Brown); (2) entitled to deduct a greater amount of charitable contributions under section 170 than allowed by respondent; and (3) liable for the addition to tax under section 6651(a)(1) for failing to timely file their 1998 return. At the time the petition was filed petitioners resided in Westfield, New Jersey. Background Mr. Brown has been an attorney for 30 years. In 1998, he worked full-time for a company called Mecca and part-time with his own law practice. Petitioner Linda L. Brown (Mrs. Brown) operated a child day care services business. Each filed a Schedule C for the respective business, but only items concerning Mr. Brown’s Schedule C are in dispute.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011