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For the 2 years at issue, the disallowed deductions consisted of
charitable contributions, job expenses, and other miscellaneous
deductions.
The disallowed deductions consisted of the following amounts
claimed on petitioners' returns:
1999 2000
Charitable contributions
Cash $5,744 $3,900
Noncash 413 $ 6,157 2,000 $5,900
Unreimbursed employee expenses* 14,217 6,785
Tax preparation fees* 900 --
*Before deduction of the sec. 67(a) limitation.
At trial, petitioners alleged that their actual charitable
contributions for the 2 years in question approximated the
amounts claimed on their returns; however, they admittedly
included in these numbers the approximate value of gifts to
members of their respective families and friends for birthdays,
graduations, weddings, and holidays. For 2000, the noncash gifts
included a BMW vehicle that petitioners donated to their former
minister, which they intended to be a gift to him personally and
not a gift to his church.
The manner in which Mr. Beltran prepared petitioners' tax
returns for the 2 years at issue was described by petitioner as
follows:
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