Steve D. Putnam - Page 5

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          expenses because computers were available to TI employees in the            
          office.  Petitioner deducted these computer-related purchases on            
          Schedule A.                                                                 
               Petitioner purchased birthday gifts for two of his                     
          customers.  During 1993, he purchased a gift certificate,                   
          flowers, and merchandise from a ski shop for these customers.               
          These expenses were deducted by petitioner as business expenses.            
               None of petitioner’s 1993 expense reports were declined.               
          Petitioner did not submit any of the above-mentioned expenses for           
          reimbursement.                                                              
               On his 1993 tax return petitioner claimed the following as             
          unreimbursed employee expenses:  Travel $3,862, meals and                   
          entertainment $4,225,4 and gifts $214.  For other miscellaneous             
          itemized deductions, petitioner claimed a deduction of $214 for             
          computer services and $167 for professional publications.                   
          Petitioner also claimed vehicle expenses and parking fees as                
          unreimbursed employee expenses in the amount of $5,201.  However,           
          petitioner conceded at trial that he received a reimbursement for           
          auto expenses from TI in the amount of $5,588.27.  While there              
          were numerous other expenses claimed, these were the only items             
          that were raised at trial by petitioner.5                                   

          4  The amount for meals and entertainment was reduced by                    
          petitioner to $2,362 in a brief filed after trial.                          
          5  Petitioner has the burden of proof concerning all                        
                                                             (continued...)           




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