- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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