Steven L. and Laura J. Chambers - Page 11




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               Petitioners also claimed work/tool expenses of $216.41,                
          $319.82, and $270.16 for 1997, 1998, and 1999, respectively.                
          Although petitioners presented a list of the various retail                 
          places where the expenses were incurred, at places such as Home             
          Depot, Pep Boys, Harbor Freight, and others, no documentation was           
          presented describing the tools or other merchandise that was                
          purchased and the need for or the use of such merchandise in                
          connection with their employment.  The Court, therefore, rejects            
          petitioners' claim to an allowance of work/tool expenses for the            
          years in question.                                                          
               As noted above, petitioners claimed deductions for tax                 
          preparation fees for each of the years in question.  The Court              
          need not pass upon the substantiation of these expenses because             
          these expenses, even if allowable, would not exceed 2 percent of            
          petitioners' adjusted gross income under section 67(a).                     
               Petitioners contend they should be absolved of liability for           
          the section 6662(a) penalties because they relied on the                    
          representations of their return preparer.                                   
               The Court is satisfied that petitioners knew that the                  
          amounts deducted on their tax returns for charitable                        
          contributions and employee business expenses were false.  They              
          even submitted records to their return preparer that purportedly            
          would have substantiated their deductions, which their preparer             
          declined to use.  Petitioners knew they could only deduct                   





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