Stephen F. Scofield and Nancy E. Scofield, (1997)
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Stephen F. Scofield and Nancy E. Scofield, (1997)
T.C. Memo. 1997-547
UNITED STATES TAX COURT STEPHEN F. SCOFIELD AND NANCY E. SCOFIELD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14305-95. Filed December 11, 1997.Stephen R. Klorfein and Benjamin I. Fink, for petitioners. Lourdes Gonzalez de Mendoza, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined deficiencies in petitioners' income taxes and additions to tax as follows: Additions to tax Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 1985 $56,672 --1986 6,343 $18,577 $5,511 1 21987 90,373 23,940 4,788 21988 148,173 7,409Additions to tax Sec. Sec. Sec.Year 6653(a)(1) 6653(a)(2) 6661 1985 $2,843 3$14,115 1986 --1987 22,319 1988 7,409 21,0783 (2) Whether petitioners may deduct legal expenses of $10,243 in 1986, $59,352 in 1987, and $104,156 in 1988. We hold that they may, subject to the 2-percent limit in section 67.Unless otherwise indicated, section references are to the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioners Petitioners Stephen F. Scofield (petitioner) and Nancy E.Scofield (Mrs. Scofield) are married and lived in Marietta, Georgia, when they filed their petition. Petitioners have been married since 1981 and have four sons.Petitioner graduated from Syracuse University in 1968 with a degree in economics. He started to work in the newsprint industry that year. He worked for Great Northern Paper Co. (Great Northern) from 1968 to June 1972, pr...See the full content of this document
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