Tippin v. Commissioner
United States Tax Court
P is an attorney who operates his law practice as a sole proprietorship. During the years under consideration, he had six employees. The IRS filed Notices of Federal Tax Liens against Ps. The tax liens related to Ps' unpaid Federal income tax liabilities, interest, and penalties for 1983, 1984, 1985, and 1986, totaling approximately $ 67,000. Subsequently, P filed for protection under ch. 11 of the Bankruptcy Code.
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P is an attorney who operates his law practice as a sole proprietorship. During the years under consideration, he had six employees. The IRS filed Notices of Federal Tax Liens against Ps. The tax liens related to Ps' unpaid Federal income tax liabilities, interest, and penalties for 1983, 1984, 1985, and 1986, totaling approximately $ 67,000. Subsequently, P filed for protection under ch. 11 of the Bankruptcy Code. At that time, receivables due P's law practice totaled approximately $ 20,000. P filed an application to use the receivables of his law practice. The bankruptcy court ordered P to…
1Opinion of the Court
OPINION
Jacobs, Judge:
Respondent determined the following deficiencies in, and additions to, petitioners’ Federal income taxes:
Accuracy-related Additions to tax penalty
Sec. Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1) 6661 6662(a)
$1,219 $1,970 1988 $7,879 CD •<! O
$2,855 1989 14,274 -3 M tN
3,416 1990 17,079
After concessions,1 the issues for decision are: (1) Whether petitioners are entitled to Schedule C deductions for bankruptcy court-ordered adequate protection payments made during 1988, 1989, and 1990; (2) whether petitioners are entitled to Schedule C deductions for wages paid…
2Cases cited24 opinions
- United Sav. Assn. of Tex. v. Timbers of Inwood Forest Associates, Ltd.Supreme Court of the United States · 1988
- Neely v. CommissionerUnited States Tax Court · 1985
- Louisville Joint Stock Land Bank v. RadfordSupreme Court of the United States · 1935
- United States v. GilmoreSupreme Court of the United States · 1963
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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3Cited by11 opinions
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