Richard Orin Berge - Page 3

                                        - 2 -                                         
               Respondent determined a deficiency in petitioner’s Federal             
          income tax of $3,346 for the taxable year 2000.                             
               After concessions,1 the issues for decision are:  (1)                  
          Whether petitioner is entitled to a Schedule C car and truck                
          expense deduction in excess of the amount allowed by respondent;2           
          and (2) whether legal fees associated with the settlement of a              
          legal action are ordinary and necessary business expenses                   
          properly deductible on Schedule C.                                          
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in Los           
          Angeles, California, on the date the petition was filed in this             
          case.                                                                       
               Petitioner graduated from Southwestern University Law School           
          in Los Angeles, California, in December 1998.  Petitioner was               
          admitted to the State Bar of California on July 26, 2000.  Also,            
          during taxable year 2000, petitioner became a certified public              
          accountant in the State of California.                                      


          1Petitioner concedes that he is not entitled to deductions                  
          claimed on Schedule A, Itemized Deductions, of $3,255.                      
          2Petitioner claimed a car and truck expense deduction of                    
          $5,126 on his 2000 Schedule C, Profit or Loss From Business.                
          Respondent, in the notice of deficiency, disallowed $2,710 of the           
          claimed Schedule C car and truck expense deduction.  Thus,                  
          respondent allowed petitioner a car and truck expense deduction             
          for taxable year 2000 of $2,416.                                            




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