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in 1 day. Through this process, petitioner was offered and
accepted a job in 1994 in Round Valley, California.
Petitioner's 1993 Federal income tax return was filed on
April 15, 1996. His adjusted gross income for 1993 was $44,236.
Petitioner elected to itemize deductions and computed the taxable
income and Federal income tax liability reported on his return
accordingly. Relevant for our purposes, petitioner claimed
miscellaneous itemized deductions totaling $14,984 on the
Schedule A included with his 1993 return. That deduction is
composed of the following items:
Unreimbursed employee expenses $12,463
Home office expense 2,521
The unreimbursed employee expenses relate to traveling expenses
petitioner claims to have incurred in looking for employment as a
school principal.
In the notice of deficiency respondent disallowed the
claimed miscellaneous itemized deductions. Respondent further
determined that petitioner is liable for an addition to tax of
$100 under section 6651(a)(1) for his failure to file a timely
1993 Federal income tax return.
OPINION
Petitioner claimed a $2,521 home office deduction on his
1993 return. According to petitioner, he computed the amount of
the deduction on the basis of an examination of his Federal
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