Regina B. Jackson - Page 5




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               facts filed in the court, the respondent contended that                
               other issues remained unsubstantiated by petitioner.                   
               Petitioner agreed with respondent's dispute that the                   
               remaining issues were not provided to respondent.  They                
               were not available at the time.  Petitioner provided                   
               testimony under oath before the court on the remaining                 
               issues in an effort to substantiate her itemized                       
               deductions.                                                            
          Petitioner's testimony, however, failed to establish that the               
          State income tax refunds that she received in 1993 were not                 
          includable in her taxable income or that she incurred deductible            
          expenses in the amounts that she claimed.  With respect to the              
          State tax refunds, she presented no evidence that the amounts               
          deducted were not previously claimed as itemized deductions                 
          consistent with her pattern for the years in issue.  She                    
          presented no evidence of actual payments of educational expenses            
          or job search expenses.  It appears that the educational expenses           
          at least in part led to her master's degree and are not                     
          deductible even if paid.  Certain travel expenses that she                  
          claimed apparently were eligible for reimbursement by her                   
          employer.  Petitioner has provided us with no basis for allowing            
          any deductions in these categories.                                         
               With respect to her contributions to a church, she testified           
          that she attended a church "maybe every other Sunday, sometimes             
          during the winter maybe once a month or every other month or so"            
          and:                                                                        








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