- 10 -
reimbursement from his or her employer, even though not obtained,
the expense is not deductible. Stolk v. Commissioner, 40 T.C.
345, 356 (1963), affd. 326 F.2d 760 (2d Cir. 1964); Orvis v.
Commissioner, T.C. Memo. 1984-533, affd. 788 F.2d 1406 (9th Cir.
1986).
Petitioner claims other business expenses in the amount of
$7,210.54. She has presented no receipts or other evidence that
she actually incurred the expenses. Her substantiation consists
of a listing of the expenses she prepared shortly before trial,
which was admitted as a summary of her testimony. Thus,
petitioner has not substantiated the expenses and is not entitled
to a deduction. See sec. 1.162-17(d)(2), Income Tax Regs.
Charitable Contribution
Petitioner claims a charitable contribution deduction of
$6,600. Respondent argues that she has not substantiated the
deduction. In her return, petitioner claimed a $4,600 noncash
charitable contribution deduction; in a conference with the IRS
after the return was filed, she claimed an additional $2,000
deduction. Of the $4,600 deduction claimed on the return, $4,000
was for clothing. The additional $2,000 deduction was also for
clothing. The remaining $600 was for various items such as
furniture, electronic equipment, and household appliances.
Under the regulations, substantiation requirements for gifts
of property other than money vary depending on the amount of the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011