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section 475(f) election for his taxable year 2000. Unless
otherwise indicated, all section references are to the Internal
Revenue Code, as amended, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated.
The parties’ stipulations of fact are incorporated in this
Opinion by reference and are found as facts in the instant case.2
At the time of filing the petition, petitioner resided in
Birmingham, Alabama. Petitioner is an attorney who practiced
personal injury law in Birmingham, Alabama, for approximately 34
years. During January 1994, petitioner began representing
certain plaintiffs in a national class action lawsuit that
settled with the defendants during 1999. Petitioner received
approximately one-half of his compensation for settling the class
action suit during the taxable year 1999 and the other half
during the taxable year 2000. Petitioner reported net profits of
$18,520,775 and $16,966,055 from his law practice on line 29 of
Schedule C, Profit or Loss From Business, of his Forms 1040, U.S.
Individual Income Tax Return, for taxable years 1999 and 2000,
respectively.
2The instant case was tried in the Court’s Electronic
(North) Courtroom where evidence was presented electronically and
certain testimony was taken by video conference. In addition to
the usual paper format, the parties filed briefs on CD Rom.
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