-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007