Charles A. Brown, Jr. and Linda L. Brown - Page 3

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               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.                                      











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