Nathaniel L. Ward, Sr. and Irene E. Ward - Page 8

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          v. Commissioner, supra at 543-544, we find that petitioners are             
          entitled to $500 in contributions for each of the 3 taxable                 
          years.                                                                      
               Petitioners purchased supplies, teaching aides, and computer           
          items in connection with their teaching activity.  In addition,             
          petitioners had expenditures for the maintenance of their                   
          computers.  To some extent, the computers were used for personal            
          purposes.  At trial, petitioners provided some documentation of             
          their expenditures concerning their employee business expenses.             
          The amounts documented were less than one-half of the amounts               
          claimed for 1992 and 1993.  However, some of the documentation              
          for one year provided a basis for allowance of a similar amount             
          in the other year.  For example, petitioners provided                       
          substantiation of $771.92 for union dues in 1993, and respondent            
          conceded that amount.                                                       
               The claimed deductions relating to computers are subject to            
          the more rigorous requirements of section 274(d) because they are           
          "listed property" as described in section 274(d)(4) and listed in           
          section 280F(d)(4)(A)(iv).  See also sec. 1.274-5T(a), Temporary            
          Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).  In that               
          regard, petitioners provided specific proof of computer                     
          expenditures during 1992 and 1993 in the amounts of $1,224.40 and           
          $1,668.93.  Taking into consideration personal use, we hold that            
          petitioners are entitled to employee computer-related business              






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