Gary S. and Julie A. Brown - Page 3




                                         -2-                                          
          this opinion shall not be treated as precedent for any other                
          case.                                                                       
               Respondent determined a $6,271 deficiency, a $1,698.15                 
          section 6651(a)(1) addition to tax, and a $1,254.20 section                 
          6662(a) accuracy-related penalty with respect to petitioners’               
          1997 Federal income tax.                                                    
               The issues for decision are:  (1) Whether petitioners are              
          entitled to a trade or business expense deduction for rent in               
          excess of the amount allowed by respondent; (2) whether                     
          petitioners failed to file a timely 1997 Federal income tax                 
          return, and if so, whether their failure was due to reasonable              
          cause; and (3) whether the underpayment of tax required to be               
          shown on petitioners’ 1997 Federal income tax return is due to              
          negligence or intentional disregard of rules or regulations.                
                                     Background                                       
               Some of the facts have been stipulated and are so found.  At           
          all times relevant petitioners were married to each other.2  They           
          filed a joint Federal income tax return for 1997.  References to            
          petitioner are to Gary S. Brown.                                            
               Petitioner is an attorney.  During all times relevant, he              
          conducted the practice of law as sole proprietorship in the Los             
          Angeles, California, area.  From May 1992 through November 1995,            


               2 Petitioners separated and divorced from each other                   
          following the year in issue.                                                






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