- 8 - 1992 and 1993, respectively, which represents the excess of petitioner's verified itemized deductions of $12,156 and $11,942, respectively, over the standard deductions claimed by petitioner for those years. Respondent concedes that during the Appeals conference, respondent allowed itemized deductions in the total amounts of $12,434 for 1992 and $12,273 for 1993. However, the following itemized deductions were disallowed due to lack of substantiation: 1992 1993 Safe deposit rental $ 119 Moving expenses 800 Charitable contributions $3,100 3,757 Casualty/theft loss 52,000 ______ _______ Total $3,100 $56,676 On brief, petitioner mentioned without discussion the additional itemized deductions issue, but did not address this issue at trial. Accordingly, we conclude that petitioner has conceded this issue. Petitioner is not entitled to any itemized deductions other than those allowed by respondent. Even though petitioner had not claimed rental expenses on his 1992 and 1993 returns, at trial he raised the issue that he was entitled to claim rental expenses as a lessor for those two years. He admitted he rented the property for only two months in 1991. He presented no credible evidence of any expenses for 1992 and 1993. On this record, petitioner has failed to substantiatePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011