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Federal income tax returns. On the 1997 return, petitioners
claimed itemized deductions totaling $21,622, for 1998 the
itemized deductions totaled $24,811, and for 1999 the deductions
totaled $14,250. In the notice of deficiency, respondent
disallowed $13,968, $15,910, and $14,250, respectively, of the
itemized deductions for the 3 years in question.3
At the time petitioners met with Mr. Beltran for preparation
of their 1997 return, they were aware and knew that documentary
information was necessary to substantiate the income and expenses
reported and claimed on their returns. They presented such
information to Mr. Beltran; however, as Mrs. Chambers testified
at trial: "We handed Robin everything we had and he handed it
back to us, stating that he didn't need to see what we had."
The only adjustments in the notice of deficiency relate to
petitioners' itemized deductions for the 3 years in question. On
their 1997 return, petitioners claimed an itemized deduction of
$5,842 for medical and dental expenses, prior to application of
the 7.5-percent limitation under section 213(a). Respondent
disallowed the amount claimed for lack of substantiation.
3 For 1997 and 1998, other claimed itemized deductions
were not adjusted, and the total of such allowed deductions
exceeded the standard deduction under sec. 63(c). Petitioners,
therefore, were allowed itemized deductions for these 2 years in
the notice of deficiency. For 1999, petitioners were allowed the
standard deduction under sec. 63(c).
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