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After concessions,1 the issues for decision are: (1)
Whether petitioner is entitled to deduct expenses in the amount
of $550 incurred in the rental of formal wear for the 1994 tax
year, and (2) whether petitioner is entitled to deduct $530 for
luggage stolen in 1994.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in San Diego, California.
Petitioner, a teacher in San Diego, was named California
State Teacher of the Year in 1993. In 1994, petitioner was named
National Teacher of the Year for her work in educating homeless
children.
After receiving the National Teacher of the Year award from
the President of the United States, petitioner took a year-long
paid sabbatical from her teaching job in San Diego in order to
lecture on the importance of educating homeless children.
Petitioner reported $9,806 in gross receipts from her
speaking engagements as a lecturer on Schedule C of her 1994
Federal income tax return. Petitioner deducted the following
expenses totaling $15,762 on Schedule C:
1
Petitioner concedes that she is not entitled to deduct
Schedule C expenses in the amount of $1,110 for home maintenance
and $7,671 of the amount deducted as "Uniform/Dry Clean/Rental".
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