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Thornton was supervisor of the communications center for an
ambulance service.
On their joint Federal income tax returns for 1999 and 2000,
petitioners reported adjusted gross income of $74,949 and
$85,228, respectively. For both years, petitioners claimed
itemized deductions under section 63(d) reflected on Schedule A,
Itemized Deductions, of their returns.
In the notice of deficiency, respondent disallowed the total
amounts claimed as itemized deductions for charitable
contributions and unreimbursed employee business expenses.
Petitioners had claimed the following amounts on their returns:
1999 2000
Charitable contributions $6,260 $ 7,200
Unreimbursed employee expenses and tax
preparation fees (before the sec.
67(a) limitation) 9,394 11,440
At least for the 2 years prior to the years at issue,
petitioners did not utilize the services of a preparer in filing
their Federal income tax returns. Petitioner prepared the
returns himself. For the 1999 return, petitioner prepared a
return as he had done in past years. Based on that draft,
petitioner testified that he and his wife would have owed $1,500
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