-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 Next
Last modified: November 10, 2007