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After concessions, the issues for decision are: (1) Whether
petitioner is entitled to a deduction for charitable
contributions; (2) whether petitioner is entitled to deduct
unreimbursed employee automobile expenses; and (3) whether
petitioner is entitled to deduct automobile expenses from her
Amway business.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioner resided in
Fairfield, California, at the time her petition was filed.
Background
In 1995 petitioner resided in Yuba City, California, and
worked as an apprentice ironworker. She received job assignments
through a union hall located in Sacramento, California, and
worked in various locations in California during 1995, including
63 days in Salinas, 49 days in Santa Cruz, 22 days in Sacramento,
16 days in Modesto, 13 days in Stockton, and 11 days in San
Francisco. Between jobs petitioner reported to the union hall in
the morning, and if there was work available, she would then
drive from the union hall to the job site. After obtaining work,
petitioner reported directly to the job site until the job was
completed.
On Schedule A, Itemized Deductions, of her Form 1040, U.S.
Individual Income Tax Return, petitioner claimed itemized
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