-3-
his law offices were located in leased space pursuant to a
sublease (the lease)3 petitioner entered into with a Georgia
partnership (the lessor). As relevant here, the lease obligated
petitioner to make rental payments of $3,700 per month from
January through October 2003, and $6,900 per month thereafter.
Petitioner paid only portions of the rent due under the lease
during 1993 and 1994, and he made none of the rent payments due
under the lease during 1995, as shown on the following table
(amounts are rounded and include incidental charges):
Year Rent (Annual) Due Per Lease Rent Paid
1993 $55,395 $43,900
1994 84,738 57,248
1995 84,915 - 0 -
In connection with his law practice, petitioner also rented
a storage facility where he stored client records. He paid $500
per month for the storage facility throughout the years 1993
through 1995.
Towards the end of 1995, petitioner’s rental arrearages
under the lease were substantial. As it turned out, he was sued
by the lessor in October 1995, and according to petitioner “the
amount in controversy” in that lawsuit “exceed[ed] $100,000”.
Ultimately the law suit was settled by agreement between
petitioner and the lessor. In accordance with that settlement
3 The term of the sublease ran from May 15, 1992 until
Sept. 30, 1996.
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