- 4 -
1997 1998 1999
Charitable contributions $ 2,639 $3,525 $3,941
Unreimbursed employee expenses
(before the sec. 67(a)
limitation) 12,923 9,063 8,221
Petitioners agreed at trial that their actual charitable
contributions were far less than the amounts claimed on the
returns. They provided documentation of $250 for 1998
contributions, $435 for 1999, and no proof of any contributions
during 1997.2 The unreimbursed employee expenses were all
related to petitioner's employment. Petitioner readily admitted
that the amounts above were far in excess of what he actually
expended. For example, the $12,923 shown above for 1997 was
related to petitioner's construction work, for which he earned
$20,249 in wages that year. Thus, the amount claimed for
unreimbursed employee expenses for that year represents
approximately 64 percent of the wages earned in connection with
that employment. Petitioner agreed that he would not, in the
real world, accept employment where unreimbursed employee
expenses would be of such magnitude.
2 The Court notes that, as stated earlier, petitioners
conceded the deficiencies in the stipulation, and any amounts
substantiated at trial would be less than the standard deduction;
consequently, there are no grounds for disregarding the
stipulation as in Jasionowski v. Commissioner, 66 T.C. 312
(1976).
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011