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contribution. Petitioner contended that his noncash
contributions were in excess of $500 for each of the years in
question. However, neither of his returns included IRS Form
8283, Noncash Charitable Contributions, which is required under
section 1.170A-13(b)(3), Income Tax Regs., relating to deductions
in excess of $500 for charitable contributions of property other
than money. Moreover, the Court is satisfied from the record
that the amounts deducted as charitable contributions on
petitioner's returns were arbitrarily determined by the return
preparer. On this record, the Court sustains respondent on the
disallowed charitable contribution deductions for 1999 and 2000.
With respect to the second issue, the employee expenses,
petitioner claimed $11,153 and $9,600, respectively, for 1999 and
2000, for unreimbursed employee business expenses, prior to
application of the limitation under section 67(a). The expenses
claimed relate to petitioner's use of his personal vehicle in
connection with his employment, as well as other expenses,
including a telephone and a pager. Petitioner was required as a
condition of his employment to travel to places that required
overnight stays, while other uses of his vehicle were not away
from home. The expenses claimed represent approximately 20.9
percent and 26.8 percent, respectively, of petitioner's wages for
the 2 years in question.
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