- 4 -
1998 1999
Charitable contributions $ 5,299 $ 7,071
Unreimbursed employee expenses and
tax preparation fees (before the
sec. 67(a)limitation) 11,632 18,082
Petitioners acknowledged at trial that their actual
charitable contributions were considerably less than the amounts
claimed on their returns but ventured no estimate as to the
correct amount of their actual contributions. They presented
meager evidence reflecting nominal contributions to
organizations, such as the Fraternal Order of Police and Special
Olympics of New Mexico, as well as a handwritten list of clothing
and other items donated to "Joy Junction" during one of the years
at issue.
The unreimbursed employee expenses claimed represented
expenses incurred by Mr. Lavigne in the use of his personal
vehicle in connection with his employment. No logs or other
records were maintained by him with respect to these expenses.
With respect to the first issue regarding petitioners'
entitlement to deductions for unreimbursed employee business
expenses, petitioners did not maintain logs or other records to
substantiate the amounts claimed for such expenses on their
returns. Such deductions are subject to the strict
substantiation requirements of section 274(d). In the absence of
records that would satisfy section 274(d), the Court holds that
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