Michel L. Dixon - Page 4




                                        - 4 -                                         

          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                 






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011