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decision are: (1) Whether petitioners are entitled to deduct
legal fees of $84,542 from their adjusted gross income pursuant
to section 62(a)(1), or whether petitioners must deduct the legal
fees as a miscellaneous itemized deduction under section 67; and
(2) whether petitioners are liable for an accuracy-related
penalty under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time they filed their petition, petitioners
resided in West Roxbury, Massachusetts.
Philip T. Chaplin (petitioner) is a professional fiduciary,
serving as a trustee of trusts and as an executor of estates.
Petitioner began his career with Minot, DeBlois & Maddison (MDM)
in 1979. Before his employment with MDM, petitioner had no
experience with investment management or trust and estate
administration.
On October 27, 1983, Rice, Heard & Bigelow, Inc. (RHB), a C
corporation incorporated in the Commonwealth of Massachusetts,
was formed as a spinoff of MDM. Upon its incorporation,
petitioner went to work with RHB and participated in RHB’s
1(...continued)
as amended. Amounts are rounded to the nearest dollar.
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