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the year in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s Federal
income tax for the year 2001 in the amount of $22,502.42. The
issues for decision are whether petitioner is entitled to a
deduction for State and local taxes paid in the year in issue,
and whether petitioner is entitled to deductions for other
miscellaneous business expenses and tax preparation fees in 2001.
Background
The stipulation of facts and the attached exhibits are
incorporated herein by reference. At the time the petition was
filed, petitioner resided in Chicago, Illinois.
Petitioner is a criminal defense attorney based out of
Chicago, Illinois, with clients in several States. Petitioner
filed his Federal income tax return for 2001 listing the
following deductions on Schedule A, Itemized Deductions:
State and local income taxes $19,400
Gifts by cash or check 250
Tax preparation fees 12,721
Other miscellaneous deductions
(books, seminar expenses, dues) 5,750
Other business expenses
(entertainment & promotion) 4,600
On July 7, 2005, respondent mailed petitioner a notice of
deficiency, disallowing all of the deductions listed on
petitioner’s Schedule A, with the exception of the deduction
claimed of $250 in Gifts by Cash or Check.
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