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Discussion
As noted above, petitioner now agrees that she underreported
her wages from the City of New York on her 2000 return. She now
challenges respondent’s refusal to adjust the deficiency here in
dispute to take into account the deductions claimed on the
Schedules A and C attached to her amended return.
1. Itemized Deductions
In computing an individual’s taxable income, the individual
may elect to itemize deductions. Sec. 63(b), (d) and (e). The
election is made on the individual’s return. Sec. 63(e)(2). In
the absence of such an election, the individual’s taxable income
is computed with reference to the standard deduction. Sec. 63(b)
and (c). Here, petitioner did not elect to itemize deductions on
her 2000 return, but she elected to do so on the amended return.
This she is entitled to do. Sec. 63(e)(3); sec. 1.63-1(a),
Income Tax Regs. Nevertheless, she is required to substantiate
the deductions claimed on the Schedule A included with the
amended return. Sec. 6001; Hradesky v. Commissioner, 65 T.C. 87,
90 (1975); affd. per curiam 540 F.2d 821 (5th Cir. 1976); sec.
1.6001-1(a), Income Tax Regs. Furthermore, to have any
consequence here, the total of the allowable itemized deductions
must exceed the standard deduction; i.e., $6,450.
Mathematically, the itemized deductions claimed on the
Schedule A can exceed the standard deduction only if all, or at
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