L.S. Vines - Page 3

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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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