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Petitioners allocated 90 percent of the automobile for business use
and 10 percent for personal use.
Dr. Novick received reimbursement from his employer for
claimed employee business expenses. Petitioners presented no
documentation at trial to substantiate any of the disallowed
miscellaneous employee business expenses.
Charitable Contributions
For each of the years under consideration, petitioners claimed
a deduction for charitable contributions. The following table
shows the amounts of charitable contributions claimed by
petitioners, and the amounts allowed and disallowed by respondent,
for each of the years under consideration:
1989 1990 1991
Claimed $15,145 $21,111 $25,443
Allowed 13,421 15,450 18,931
Disallowed (at issue) 1,724 5,661 6,502
Petitioners presented no documentation at trial to
substantiate their claims for charitable contributions in excess of
those allowed by respondent.
Investment Interest
Petitioners claimed a $15,000 investment interest deduction on
their 1990 tax return which was disallowed by respondent. As best
we can glean from the record (which with respect to this item is
inadequate), the deduction relates to interest on a $50,000 loan
secured by a life insurance policy with General Services Life
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