Eugene I. and Leonarda T. Valdez - Page 5




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          1997      1998      1999                                                    
          Charitable contributions        $3,957    $3,030    $3,736                  
          Unreimbursed employee expenses                                              
          (before the sec. 67(a)                                                      
          limitation)                     6,577     7,710     4,775                   

               Petitioners agree that they did not incur any unreimbursed             
          employee expenses during the 3 years at issue and had no                    
          intention of claiming such expenses as deductions on their                  
          returns.  Even though petitioners made some charitable                      
          contributions during the years at issue, they maintained no                 
          records of their contributions and, likewise, had no intent to              
          claim such contributions as deductions.  Petitioner's only                  
          explanation for the inclusion of such items on their returns was            
          that the amounts on the returns simply "came out of his [Mr.                
          Beltran's] head."                                                           
               Petitioners never examined the returns prepared by Mr.                 
          Beltran except for the amounts claimed on the returns as refunds            
          for overpayments.  Mr. Beltran advised petitioners to ignore any            
          correspondence they received from the Internal Revenue Service              
          questioning their returns, and petitioners followed that advice.            
               Petitioners contend they should be absolved of liability for           
          the section 6662(a) penalties because they relied on the                    
          representations of their return preparer.                                   








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