Gary S. and Julie A. Brown - Page 5




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          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              







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