Sandra Holmes - Page 3
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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
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.
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Last modified: November 10, 2007