- 4 -
For the years in question, petitioners claimed the following
itemized deductions on their returns, which were disallowed in
full by respondent in the notice of deficiency:
1998 1999
Charitable contributions $ 6,925 $ 7,272
Unreimbursed employee expenses and
tax preparation fees (before the
sec. 67(a)limitation) 12,770* 15,515*
* As noted supra note 2, the parties settled this
adjustment.
Petitioners acknowledged at trial that their actual
charitable contributions were considerably less than the amounts
claimed on their returns. They estimated their actual charitable
contributions to be approximately $2,000 for each year. However,
on their 1996 and 1997 tax returns, which were offered in
evidence by respondent, their contributions were $520 and $545,
respectively, for 1998 and 1999, and they made no claim for job
expenses and other miscellaneous deductions on their returns for
these 2 years.
With respect to the charitable contributions issue,
petitioners' testimony at trial satisfies the Court that the
amounts claimed were arbitrarily determined by the return
3(...continued)
ignore all correspondence they received concerning their tax
returns.
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