-4-
agreement, payments totaling $137,150 were made by petitioner to
the lessor during 1997. Petitioner vacated the premises covered
by the lease as of November 30, 1995. As best can be determined
from the record, petitioner relocated his law offices and
continued his law practice sometime towards the end of 1995 or
beginning of 1996.
Petitioners filed joint Federal income tax returns for the
years 1993, 1994, and 1995. Each of the those returns includes a
Schedule C, Profit or Loss From Business, on which items of
income and expense deductions relating to petitioner’s practice
of law are claimed. Each Schedule C shows a deduction for “rent”
“other business property” as follows:
Year Amount
1993 $48,493
1994 65,852
1995 85,092
Petitioners also filed a joint Federal income tax return for
1997, and that return also includes a Schedule C relating to
petitioner’s law practice. As relevant here, on that Schedule C
petitioner claims a $23,822 deduction for “rent” “other business
property”. During the course of the examination of petitioners’
1997 return, an amended Schedule C was submitted to the revenue
agent conducting the examination. The amended Schedule C shows a
$160,972 deduction for “rent” “other business property”,
consisting of the amount originally claimed, plus the $137,150
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: November 10, 2007