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petitioner claimed employee business expenses (prior to the
limitation provided by section 67(a)) as follows:
Year Amount
1991 $9,023
1992 8,491
1993 9,530
The returns in issue were prepared by Space Coast Bookkeeping and
Taxes, Inc. (Space Coast).
In the notice of deficiency, respondent disallowed the
claimed employee business expense deductions. At trial
respondent conceded that the itemized deductions claimed by
petitioner were incurred and paid. Respondent also conceded that
petitioner is entitled to a portion of the claimed deductions.2
OPINION
Respondent asserts that petitioner has failed to establish
that the claimed expenses, over and above those allowed, are
ordinary and necessary business expenses incurred while carrying
on petitioner's trade or business as an employee. Petitioner
argues that the Internal Revenue Service (IRS) acted unfairly in
examining his returns, and that the examination was the result of
2 Respondent agreed that petitioner is entitled to deduct
60 percent of the claimed automobile expenses for each of the
years in issue. Also respondent agreed that petitioner is
entitled to deduct $510, $501, and $510 for the taxable years
1991, 1992, and 1993 respectively, relating to claimed employee
business expenses other than vehicle, parking fee, toll, and
travel expenses.
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