Richard A. Gerstenberger - Page 7




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            Line on                                           Amount of               
           Form 2106        Nature of Claimed Expense      Claimed Expense            
               1                 Vehicle expense                  -                   
               2         Parking fees, tolls, and trans-          -                   
                                    portation                                         
               3         Travel expense while away from        $1,900                 
                                 home overnight                                       
               4        Business expenses not included on      8,7221                 
                                lines 1 through 3                                     
               5        Meals and entertainment expenses       1,9162                 
               1According to a separate statement attached to the 1995                
          return, the $8,722 listed in Form 2106 consisted of $6,411 for              
          supplies and $2,311 for uniforms.                                           
               2Although Form 2106 claimed $1,916 for meals and entertain-            
          ment, as required by Form 2106, only 50 percent of those expenses           
          (i.e., $958) was claimed on line 20 of Schedule A as part of                
          unreimbursed employee expenses.                                             
               The 1995 return claimed on line 21 of Schedule A $318 for              
          “Tax preparation fees” and did not claim any amount on line 22 of           
          that schedule, entitled “Other expenses”.                                   
               As required by the job-expense section of the 1995 return              
          and section 67(a) (2-percent adjustment), the total expenditures            
          claimed in that section, i.e., $13,834, were reduced by an amount           
          equal to 2 percent of the $869 of adjusted gross income reported            
          in the 1995 return, i.e., by $17.  The 1995 return claimed the              
          balance, i.e., $13,817, on line 26 of Schedule A as a deduction.            
               The 1995 return also included Schedule C, Profit or Loss               
          From Business (Schedule C), which claimed that petitioner was the           
          proprietor of a business that provided truck repair services.               
          Schedule C reported gross income of $2,500 and claimed “Total               
          expenses before expenses for business use of home” of $42,939               






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