Victor and Lorain Cisneros - Page 5




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          returns, as Mrs. Cisneros testified, represented amounts that Mr.           
          Beltran "came up with on his own".                                          
               The disallowed deductions consisted of the following amounts           
          claimed on petitioners' returns:                                            

                 1998        1999                                                     
          Charitable contributions             $ 8,365     $ 9,663                    
          Unreimbursed employee expenses and                                          
          tax preparation fees (before the                                            
          sec. 67(a)limitation)                15,600      14,032                     

               Mrs. Cisneros acknowledged at trial that their actual                  
          charitable contributions were considerably less than the amounts            
          claimed on their returns.  Mrs. Cisneros estimated that                     
          petitioners actually contributed to charity during 1998                     
          approximately $5,000, but she made no estimate for 1999.                    
          Petitioners submitted canceled checks at trial for contributions            
          totaling $30 for 1998 and $62 for 1999.                                     
               The unreimbursed employee expenses shown above allegedly               
          represented expenses incurred by Mr. Cisneros for out-of-town               
          travel in connection with his employment.  No log or other books            
          and records were offered at trial to substantiate the amounts               
          claimed.                                                                    
               With respect to the first issue, Mrs. Cisneros acknowledged            
          having won $1,000 from a lottery during 1998.  That amount was              
          not included as income on petitioners' return.  Mrs. Cisneros               






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