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deductions of $10,503. In addition to claiming deductions for
taxes paid, petitioner claimed deductions for $1,160 in
charitable gifts made to her churches and $9,297 in unreimbursed
employee expenses related to her job as an ironworker.
Petitioner included in the unreimbursed employee expenses a
deduction for $6,758 in automobile expenses based on 22,5251
miles driven from her home in Yuba City to the union hall in
Sacramento and from her home to each of the various job sites.
Petitioner used the standard rate of 30 cents per mile to compute
the deduction.
During 1995, petitioner also was engaged in marketing Amway
products. She reported gross income of $365 and expenses of
$3,712 from her Amway activity on Schedule C, Profit or Loss From
Business. The expenses included $1,801 for vehicle expenses,
$708 for utilities, and $1,203 for seminars, tapes, and books.
In the notice of deficiency, respondent disallowed $8,094 of
petitioner’s Schedule A itemized deductions and $1,582 of
petitioner’s Schedule C deductions. Respondent’s determinations
reduced petitioner’s itemized deductions to an amount less than
the allowable standard deduction. Petitioner’s tax liability,
therefore, was determined using the standard deduction for 1995.
1 Although the parties stipulated that petitioner claimed
automobile mileage deductions for 25,525 miles, petitioner’s Form
2106-EZ, Unreimbursed Employee Expenses, indicates that she
deducted the standard mileage rate for 22,525 miles.
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