Dona Elizabeth Conway - Page 14

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          Miscellaneous Itemized Deductions                                           
               With respect to the claimed $1,000 consulting fee in excess            
          of the $9,000 allowed by respondent, petitioner has failed to               
          demonstrate that the $1,000 was paid for management,                        
          conservation, or production of income or income-producing                   
          property, and we sustain respondent's disallowance thereof.                 
               With respect to the claimed $2,500 investment loss and the             
          claimed $750 legal fees, the evidence provides no basis to                  
          support these claimed deductions, and we sustain respondent's               
          disallowance thereof.                                                       

          IRA Distribution                                                            
               With regard to the $5,149 IRA distribution that petitioner             
          received from Great-West, petitioner has not established that the           
          10-percent additional tax on the $895 taxable portion of the                
          $5,149 distribution does not apply, and we sustain this                     
          additional tax.                                                             
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                        under Rule 155.                               










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