James J. McCarron III and Michelle McCarron - Page 9

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               Respondent limited petitioners deductions for cash                     
          charitable contributions to those amounts evidenced by canceled             
          checks as follows:                                                          
                                   1993      $75                                      
                                   1994      10                                       
                                   1995      60                                       
               For the $500 noncash charitable contribution claimed on                
          their 1995 return, petitioners submitted documentation consisting           
          of a Salvation Army receipt for one refrigerator and four bags of           
          clothes.  Petitioners attributed a value of $500 to the total               
          contribution.  Respondent reduced the value of the contribution             
          to $350:  $150 for the refrigerator and $50 for each bag of                 
          clothes.                                                                    
               The reduction of the charitable contribution deduction for             
          1995 reduced petitioners' total itemized deductions to $6,481.              
          The standard deduction for joint filers in 1995 was $6,550.                 
          Respondent applied the higher amount of the standard deduction in           
          calculating the tax due for 1995.                                           
               Additionally, petitioners claimed various deductions on                
          their 1993, 1994, and 1995 Schedules C for their tax preparation,           
          stock brokerage, and horse riding instruction activities.                   
          Respondent allowed deductions for the business expenses that were           
          sufficiently documented by canceled checks.  Respondent                     
          disallowed many of the deductions, including a $287 deduction for           
          self-employment health insurance, because petitioners failed to             






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