- 2 -
Respondent determined a deficiency of $23,709 in
petitioner’s Federal income tax for the year 2000, an addition to
tax under section 6651(a)(1) in the amount of $5,334.53, an
addition to tax under section 6651(a)(2), and an addition to tax
under section 6654 in the amount of $1,275.16. In the answer,
respondent conceded the section 6651(a)(2) addition to tax and,
pursuant to section 6214(a), claimed an increase in the section
6651(a)(1) addition to tax of $592.72. In a trial memorandum,
respondent conceded the section 6654 addition to tax.2
The issues for decision are: (1) Whether petitioner is
entitled to claim a deduction for miscellaneous legal expenses on
Schedule A, Itemized Deductions, in an amount exceeding what was
allowed by respondent; (2) whether petitioner is entitled to
claim deductions for various trade or business expenses
disallowed by respondent for two business activities of
petitioner reported on separate Schedules C, Profit or Loss From
2 At the time the notice of deficiency was issued,
petitioner had not filed his Federal income tax return for the
year at issue. The notice of deficiency is based upon
information returns filed by third-party payers for nonemployee
compensation, wages, and interest paid to petitioner. Petitioner
does not challenge these determinations. After the notice of
deficiency was issued, as stated in respondent’s brief,
“petitioner provided respondent with his individual income tax
return for the 2000 taxable year.” Respondent further stated on
brief: “Petitioner has never provided an explanation as to why
his return was filed late.” That statement appears to indicate
that petitioner’s return was processed as a filed return.
Petitioner does not challenge the income determinations in the
notice of deficiency, and the issues essentially involve two
trade or business activities and itemized deductions.
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