- 2 -
the decision to be entered is not reviewable by any other court,
and this opinion shall not be treated as precedent for any other
case.
Respondent determined a $24,823 deficiency in petitioner’s
2003 Federal income tax and a $4,965 accuracy-related penalty
under section 6662. The issues for decision are: (1) Whether all
payments petitioner received from his former employer, Mahoning
Valley Economic Development Corp. (MVEDC), pursuant to the
settlement of a lawsuit are includable in income; (2) whether
petitioner may deduct attorney’s fees he paid in bringing a
lawsuit against MVEDC; (3) whether petitioner paid deductible
expenses which would offset income he received in the performance
of consulting services; and (4) whether petitioner is liable for
an accuracy-related penalty under section 6662.
Background
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. At the time he filed his petition,
petitioner resided in Niles, Ohio.
Petitioner, as a married taxpayer filing separately, timely
filed a Form 1040, U.S. Individual Income Tax Return, for 2003 in
which he reported total income of $46,479, tax of $6,416, and tax
payments of $7,586. Both petitioner and his wife claimed the
standard deduction for 2003 in their separate returns.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007