- 3 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011