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original petition in this case, petitioner filed a Federal income
tax return for taxable year 1996. He reported the following
income and claimed the following deductions:
Wages $24,800.00
Unemployment compensation 4,223.00
NOL carryover (7,367.70)
Itemized deductions (19,105.30)
Personal exemption (2,550.00)
Taxable income -0-
The itemized deductions consist solely of an employee business
expense deduction comprised of the following, listed as
characterized by petitioner:
Education $7,472.56
Domestic 639.61
Rent 4,890.23
Phone (lowball est.-2 checks only) 141.40
Utilities (power) 94.36
Postal 113.15*
Xerox, printing 37.39*
Computer related (professional) 470.00*
Stationery/office supplies 716.11
Books, etc. (business related) 302.58*
Misc. fees 23.64*
Misc. major (ministorage) 195.07*
AT&T MC phone bills 130.46
Misc. mileage (3 MN-IA round trips
+ MN-PA return, 3,618 @ .31) 1,121.58*
Auto mileage (2,340 @ .31) 725.40*
Travel-related (tolls, parking,
truck for moving) 344.45*
Bus. lodging 212.42*
Food (91 days @ 34/day;
19 days @ 38/day) 3,816.00*
Less 50 percent of food (1,908.00)
Less 2 percent of adjusted gross
income (433.11)
19,105.30
*Respondent does not challenge petitioner’s substantiation of these
amounts.
1(...continued)
The tax from this calculation exactly matches the amount of the
deficiency determined by respondent. Petitioner admits receiving
the amount of income determined by respondent; the remainder of
respondent’s deficiency determination is essentially
computational.
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