Edgar and Doris Brown - Page 10

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          deficiency, respondent listed three adjustments to petitioners'             
          itemized deductions, disallowing $13,847 of those deductions.  As           
          to petitioners' deduction for charitable contributions in the               
          amount of $18,496, respondent concluded that petitioners had not            
          established that they donated any amount greater than $16,536 to            
          qualifying organizations during the tax year and, therefore,                
          reduced petitioners' deduction by $1,960.  At trial, petitioners            
          provided no evidence or testimony substantiating the additional             
          $1,960 in charitable contributions.  Consequently, as there is no           
          rational basis to approximate those contributions, we conclude              
          that petitioners have not met their burden of substantiating                
          them.                                                                       
               As to petitioners' line 21 deduction for "Job Expenses and             
          Most Other Miscellaneous Deductions" in the amount of $10,810,              
          respondent conceded that petitioners were entitled to deduct $161           
          for other miscellaneous itemized deductions (line 20 deduction).            
          Respondent, however, concluded that petitioners had not                     
          established that they paid any amount greater than $560 for the             
          unreimbursed employee expenses related to Mr. Brown's job as a              
          minister (line 19 deduction) and, accordingly, disallowed $10,089           
          of those expenses.  On the basis of the increase in petitioners'            
          gross income resulting from all of the adjustments in the notice            
          of deficiency, however, respondent determined that the allowable            
          miscellaneous expenses in the amount of $721 were less than 2               






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