Nicholas M. Romer - Page 15

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          expenses under sections 162 or 212.  Furthermore, we reject his             
          alternate argument that the disallowed expenses are deductible as           
          charitable contributions.  We are not convinced that his activity           
          benefited CAF in any way.  The record does not show that he                 
          participated in any of CAF's air shows.  Rather, the record shows           
          that during 1993 petitioner was paying CAF for his use of its               
          aircraft in order to learn how to fly World War II planes.  We              
          conclude that these expenses were personal in nature and are not            
          deductible pursuant to section 262.  We sustain respondent's                
          determination on this issue.                                                
               The fourth issue for decision is whether petitioner is                 
          entitled to Schedule A itemized deductions which exceed his                 
          claimed standard deduction for 1993.                                        
               Petitioner prepared his own return for 1993 and claimed a              
          standard deduction in the amount of $3,700 as an individual with            
          a filing status of single.  Petitioner now contends that he is              
          entitled to itemized deductions in the total amount of $13,078.             
          After carefully reviewing the record, we find that petitioner is            
          entitled to the following itemized deductions:                              
               Minnesota individual income taxes      $3,000                          
               Real estate taxes                  1,348                               
               Personal property taxes                 121                            
               Total taxes paid                             $4,469                    
               Computer donated to CAF            $1,000                              
               Sponsorship of CAF's "Miss Mitchell"       175                         
               Total gifts to charity                            1,175                
               Total itemized deductions                    $5,644                    






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