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Respondent determined deficiencies in petitioners’ Federal
income taxes of $7,073, $9,985, and $10,193 for the taxable years
1995, 1996, and 1997.
The issues for decision are: (1) Whether petitioners are
entitled to disallowed deductions for charitable contributions;
and (2) whether petitioners are entitled to disallowed deductions
for business expenses.1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
San Jose, California, on the date the petition was filed in this
case.
Petitioner husband (petitioner) was employed by Steven
Engineering, Inc., beginning around 1990 and throughout the years
in issue. Petitioner’s employment with Steven Engineering
involved the sale of electronics and related products. He earned
wages of $61,879 in 1995 and $63,293 in 1997. Petitioner wife
was employed by the County of Santa Clara, earning wages of
$8,286 in 1995 and $25,610 in 1997. Their individual wages in
1996 are not in the record, but petitioners reported combined
taxable wages of $89,546 in that year. Petitioners filed a joint
Federal income tax return for each of the years in issue.
1Adjustments to petitioners’ medical expense deductions and
miscellaneous itemized deductions are computational and will be
resolved by our holding on the issues in this case.
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