- 4 - motive for 1992 and 1993. Petitioner did not have any knowledge of the value of timber in place or whether his claimed losses had any relevance to the amount of gain he might have earned from their harvest. Petitioner’s focus was on developing a tree farm for his children or the next generation. Petitioners did not produce any documentary evidence supporting the deductions claimed on their Schedules F. Petitioners, in connection with their professional employment as teachers, paid union dues and purchased equipment and teaching aids. Petitioners claimed employee business expenses on Schedule A of their 1992 and 1993 returns in the respective amounts of $3,691.42 and $4,605. At trial, petitioners offered documentary evidence which corroborated amounts that were substantially less than those claimed on their 1992 and 1993 returns. Petitioners claimed contributions to charity by cash or check in 1991, 1992, and 1993 in the respective amounts of $3,530, $3,470, and $3,160. At trial, petitioners presented documentary evidence substantiating $10 and $25 of contributions for 1992 and 1993, respectively, and no documentary evidence was presented for 1991. Petitioner contended that he and his wife tithed at a 10-percent rate during the years in question, which would have resulted in contributions of $8,000 in each year under consideration. He offered the explanation that he claimed only about $3,000 in each year because larger claims might havePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011