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Mr. Nolen (petitioner) was employed during 1999. Petitioner
worked for several employers during the years at issue, doing
ground boring and tunneling work for the laying of underground
water lines, sewage pipes, and other types of utilities. For the
3 years in question, petitioners engaged the services of Robin
Beltran to prepare their Federal income tax returns. Mr. Beltran
had been recommended to petitioner by one of petitioner's
coworkers. When petitioners first met with Mr. Beltran, they
provided records that petitioners believed were necessary to
substantiate the deductions to be claimed on their tax returns.
Somewhat to their surprise, Mr. Beltran did not rely on those
records and represented to petitioners that the amounts to be
claimed on the returns would be allowable amounts well in excess
of their records. Petitioners accepted that position without
question. It appears that the same procedure was followed for
each of the succeeding years in question.
Respondent's determinations address two categories of
itemized deductions claimed by petitioners, which were totally
disallowed in the notice of deficiency: charitable contributions
and other miscellaneous expenses, essentially unreimbursed
employee business expenses. The following amounts were claimed
by petitioners on their returns:
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Last modified: May 25, 2011