Kingman K. Babcock and Lillian L. Babcock - Page 7

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               At trial, petitioner husband explained the $6,499 reduction            
          as follows:                                                                 
               As we went through it [the return preparer's worksheet]                
               item-by-item, I thought some items that we were using                  
               weren't primarily for the benefit of the child or the                  
               children, especially the condominium in Florida, and I                 
               * * * felt we should back those items out, so we backed                
               some items out and reduced the figure.                                 
          Petitioner husband believed their charitable deduction should be            
          more conservative than the amount calculated by their return                
          preparer.  Petitioner husband eliminated the allocated portion of           
          the fair rental value of the Florida condominium, boat, sailboat,           
          and waverunner.                                                             
               Respondent disallowed petitioners' $15,101 charitable                  
          deduction attributable to unreimbursed foster care expenses.                
               The parties stipulated that petitioners made the following             
          direct out-of-pocket expenditures for the care of their foster              
          child in 1991:                                                              
          Food                          $1,739                                        
                    Clothing/toys       2,985                                         
                    Education           150                                           
                    Babysitting         1,200                                         
                    Medical             50                                            
                    Recreation          360                                           
                    Allowance           102                                           
                    Total               $6,586                                        
               Respondent acknowledges that petitioners are entitled to a             
          charitable contribution deduction for their direct out-of-pocket            
          expenses in excess of amounts reimbursed by Monroe County.                  
          Respondent argues that although petitioners have incurred direct            





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