- 10 - 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 2Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011