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deductions being less than the tax computed on the basis of the
standard deduction.
Petitioner has conceded that he is not entitled to a medical
expense deduction for 1990, but petitioner has not conceded that
he is not entitled to the deduction he claimed for a charitable
contribution in the amount of $400. Petitioner has offered no
evidence of any charitable contribution made in 1990, and,
therefore, we sustain the denial of the deduction of $400 claimed
by petitioner for a charitable contribution in 1990.
Petitioner also deducted various expenses on his Schedule A
for the taxable year 1991 that respondent disallowed.6
Petitioner presented at trial a variety of unorganized checks,
receipts, invoices, and car rental agreements in support of these
claimed deductions.
Petitioner claimed that the unreimbursed employee business
expenses in the amount of $11,116 claimed on Schedule A of his
1991 tax return consisted of vehicle expenses, parking fees,
travel expenses, meals and entertainment expenses, and other
business expenses. Most of these claimed expense deductions are
of the type specified in section 274(d) which provides that no
deduction is allowed unless the taxpayer can substantiate by
adequate records or sufficient evidence the amount of the
6 Among the items that respondent has allowed is the
deduction of $3,600 for home mortgage interest and $285 for
points petitioner deducted on Schedule A of his 1991 tax return.
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