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deductible, as there was no evidence introduced to show that
Sacramento Sierra Medical Group (Dr. Novick's employer) required as
a condition of Dr. Novick's employment that Dr. Novick transport
the medical files to and from his home. Further, petitioners
stipulated that the storage of the medical records at their home
was not for the convenience of Dr. Novick's employer.
Petitioners claimed employee business expenses other than the
home/office and automobile expenses which were disallowed by
respondent. Dr. Novick received reimbursement from his employer
for some of these expenses. Mr. Fenton was not aware of the
reimbursement when he prepared petitioners' tax returns.
Respondent's determination with respect to the disallowed
miscellaneous employee business expenses for each of the years
under consideration is sustained.
Charitable Contributions
Section 170 allows a deduction for charitable contributions,
but only if verified pursuant to regulations. In the case at bar,
petitioners had no documentation to verify (substantiate) their
claims for charitable contributions in excess of those allowed by
respondent. Because the disallowed deductions have not been
verified, petitioners are not entitled to them.
Investment Interest
Petitioners claimed a $15,000 deduction for investment
interest on their 1990 tax return. Petitioners presented no
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