Greta Ann Clifton - Page 20

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          concedes that $1,214 of the claimed deduction is allowable.                 
               In regard to the remaining $74 at issue, petitioner                    
          testified that she could not substantiate such amount.                      
          Accordingly, we sustain respondent's determination.                         
               I.  Charitable Expense                                                 
               Petitioner claimed a charitable deduction of $50 on Schedule           
          C of her 1985 Federal income tax return, which was disallowed.              
          Subsequently, respondent allowed petitioner a $25 charitable                
          deduction on Schedule A.  Petitioner asserts that the remaining             
          $25 is allowable.                                                           
               Petitioner offered no evidence to demonstrate her                      
          entitlement to a charitable deduction in excess of that allowed             
          by respondent.  Consequently, we sustain respondent's                       
          Issue 3. Employee Business Expense Deductions                               
               Petitioner claimed a $3,150 employee business expense                  
          deduction on her 1985 Federal income tax return, which respondent           
               Since petitioner offered no evidence to substantiate the               
          deduction, she has failed to carry her burden of proof.                     
          Therefore, we affirm respondent's determination.                            
          Issue 4. Capital Loss                                                       
               Petitioner claimed a $3,000 capital loss in connection with            
          the sale of her 1985 Mustang automobile (Mustang).  Respondent              
          determined that this amount was not allowable.  Petitioner                  

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