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the respective amounts of $2,394 and $479. At the time the
petition was filed petitioner resided in Birmingham, Alabama.
The issues are whether petitioner is (1) entitled to
deductions in amounts greater than those allowed by respondent
for charitable contributions, employee business expenses, and
other miscellaneous deductions, and (2) liable for an accuracy-
related penalty for negligence under section 6662(a).
The facts may be summarized as follows. Petitioner is an
employee of the Occupational Safety and Health Administration
(OSHA). On Schedule A of petitioner's 1991 Federal income tax
return petitioner claimed deductions for the following:
Charitable Contributions $3,125
Miscellaneous Employee Business Expenses 4,088
Other Miscellaneous Deductions 5,821
Upon examination respondent disallowed portions of the claimed
deductions as follows:
Allowed Disallowed
Charitable Contributions $2,040 $1,085
Miscellaneous Employee Business Expenses 1,814 2,274
Other Miscellaneous Deductions 670 5,151
The primary difficulty with this case is that, although
petitioner prepared his return for 1991, he cannot identify with
any specificity items of contributions or expenses he claimed.
He had no documentation with regard to the disallowed amounts.
Furthermore, his testimony was unclear and often evasive.
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