Aziz A. Tokh and Susan K. Tokh - Page 4




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          in both years), shoes (four pairs at $120 each in both years),              
          hosiery ($36 and $35 per week for 50 weeks in 1996 and 1997,                
          respectively), and laundry services ($25 and $30 per week for 50            
          weeks in 1996 and 1997, respectively).  Although the remaining              
          claimed deductions for unreimbursed employment expenses were not            
          based on estimates, petitioners did not maintain any receipts,              
          records, or logbooks to prove that these expenses were actually             
          incurred.                                                                   
               Petitioners owned shares of 15 different mutual funds in               
          1996 and 16 different mutual funds in 1997.  Each mutual fund               
          passed income through to its shareholders on a net basis, i.e.,             
          gross income minus operating expenses.  In annual reports                   
          distributed to the shareholders, each mutual fund disclosed the             
          annual operating expenses incurred by the fund.  The annual                 
          operating expenses are paid by the mutual funds and are not                 
          expenses of the shareholders.  Petitioners claimed investment               
          expense deductions for a pro rata portion of the annual operating           
          expenses of the mutual funds.  Petitioners also claimed $220 in             
          1996 for Individual Retirement Account (IRA) maintenance fees.              
               Petitioners estimate that they spent $2.25 per week for 50             
          weeks on weekend issues of the Chicago Tribune.  Petitioners also           
          estimate that they sent four letters per year for each different            
          mutual fund and that they spent $40.32 per letter for typing and            
          mailing.  Petitioners claimed investment expense deductions equal           





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