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Petitioner has produced evidence from her employer that she
paid union dues in the amounts of $971.76 for 1993 and $1,163 for
1994, and respondent has conceded that these amounts are
deductible. With regard to the remaining claimed expenses,
petitioner failed to establish that she is entitled to the
deductions.
Petitioner offered no explanation concerning the
professional dues in the amounts of $67 and $320 that she
claimed, respectively, on Schedule A of her 1993 and 1994 Federal
income tax returns. There is no evidence in the record that
these dues were ordinary and necessary expenses related to her
employment.
Petitioner also claimed deductions for "Equipment and
Supplies" on Schedule A of her 1993 and 1994 Federal income tax
returns in the amounts of $1,050 and $687, respectively.
According to petitioner, her professional equipment and supplies
consisted of her "three fezzes, two hats, rituals, constitution *
* * . The books, the boxes that the fezzes and hats go in, the
equipment to keep them a certain way" and other Masonic supplies
that she was required to purchase as part of her membership in
four fraternal organizations: (1) The Eastern Star; (2) the
Cyrenes; (3) the Ladies of the Circle of Perfection; and (4) the
Daughters of Isis. Although petitioner undoubtedly purchased
certain items related to her membership in these fraternal
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