Steven L. and Laura J. Chambers - Page 5




                                        - 4 -                                         

          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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