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All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rules references are to
the Tax Court Rules of Practice and Procedure.
After concessions,1 the issues for decision are: (1)
Whether education expenses that Herbert J. Meeks (Herbert)
incurred are deductible as trade or business expenses; (2)
whether certain job-seeking and tax return preparation expenses
are deductible; (3) whether expenditures that Paula J. Meeks
(Paula) incurred are deductible as trade or business expenses;
(4) whether petitioners' boat chartering activity was an activity
engaged in for profit; and (5) whether petitioners substantiated
charitable contributions in amounts greater than respondent
concedes.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners, husband and
wife, resided in Sacramento, California, at the time they filed
the petitions in this case.
Educational Expenses
From March 1986 until sometime in 1995, Herbert was a
correctional officer with the State of California, Department of
1 Respondent concedes that petitioners may deduct $1,200 of
expenses from their boat chartering activity in 1992 pursuant to
sec. 183(b)(2).
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Last modified: May 25, 2011