Teresita T. Daiz - Page 4




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          claimed unreimbursed employee expenses on Schedule A, Itemized              
          Deductions, as follows:                                                     
            Continuing education                       $250                           
                 Books/subscriptions/etc.              420                            
                   Uniforms/maintenance          1,325                               
                 Telephone                             625                            
                 Vehicle                         17,190                              
                                                                                      
               Total                              $19,810                             
          She also deducted $192 for telephone expenses and $782 for                  
          uniform/maintenance and $1,588 for car and truck expenses, among            
          other items, on Schedule C, Profit or Loss From Business.                   
          Petitioner reported total business mileage of 59,610 miles, of              
          which 5,040 miles were reported on Schedule C.  Petitioner’s                
          income from her work in Bakersfield, unlike her income from her             
          work at the other locations, was reported as nonemployee                    
          compensation on the Schedule C.                                             
               During 1997 petitioner maintained a log of her vehicle’s               
          mileage.  According to the log, her vehicle was driven a total of           
          48,490 miles between January 16, 1997, the first day of her first           
          job assignments that year, and December 31, 1997.                           
               The record shows the number of round trips that were made as           
          well as the mileage between petitioner’s apartment in Stockton              
          and the facilities to which she drove.  The record establishes              
          that in addition to the undisputed 5,040 business miles that she            










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