- 4 - 1997 1998 1999 Charitable contributions $ 2,639 $3,525 $3,941 Unreimbursed employee expenses (before the sec. 67(a) limitation) 12,923 9,063 8,221 Petitioners agreed at trial that their actual charitable contributions were far less than the amounts claimed on the returns. They provided documentation of $250 for 1998 contributions, $435 for 1999, and no proof of any contributions during 1997.2 The unreimbursed employee expenses were all related to petitioner's employment. Petitioner readily admitted that the amounts above were far in excess of what he actually expended. For example, the $12,923 shown above for 1997 was related to petitioner's construction work, for which he earned $20,249 in wages that year. Thus, the amount claimed for unreimbursed employee expenses for that year represents approximately 64 percent of the wages earned in connection with that employment. Petitioner agreed that he would not, in the real world, accept employment where unreimbursed employee expenses would be of such magnitude. 2 The Court notes that, as stated earlier, petitioners conceded the deficiencies in the stipulation, and any amounts substantiated at trial would be less than the standard deduction; consequently, there are no grounds for disregarding the stipulation as in Jasionowski v. Commissioner, 66 T.C. 312 (1976).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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