- 3 - sexual harassment or discrimination. On September 13, 2004, because petitioner had not filed her 2001 individual Federal income tax return, respondent prepared for petitioner a substitute tax return using third-party return information and determined against petitioner a tax deficiency of $35,380, plus the additions to tax listed above. On or about September 5, 2006, 2 weeks prior to trial, petitioner signed and submitted to respondent her 2001 individual Federal income tax return and claimed thereon a $47,600 miscellaneous legal expense deduction under section 212, subject to the 2-percent adjusted-gross-income floor of section 67(a). At trial, after settling all other issues and without objection from respondent, petitioner was allowed to raise the issue as to the claimed $47,600 legal expense deduction. Of the $47,600 in legal expenses petitioner seeks to deduct, petitioner acknowledges that in 2001 she paid her attorney no more than approximately $7,000, representing out-of-pocket legal expenses. Petitioner has not submitted bills, receipts, canceled checks, or other records that would establish that petitioner paid any of the legal expenses that petitioner seeks to deduct. Petitioner admits that she is a cash method taxpayer.Page: Previous 1 2 3 4 5 NextLast modified: November 10, 2007