- 9 - among other means of transportation, the use of any passenger automobile. Sec. 280F(d)(4)(A)(i) and (ii). Petitioner presented no documentation, other than the log and other receipts referred to above, to document the use of his vehicle for local transportation in connection with his employment. Respondent, therefore, is also sustained with respect to those expenses. Petitioner also claimed other expenses incurred in his employment for a telephone and a pager. He presented no evidence to establish the amount claimed for such expenses. Consequently, no amount is allowed to petitioner for such expenses. Petitioner also claimed a deduction of $700 for tax preparation fees on his 1999 return. Although he presented no evidence to establish payment of that amount, with the disallowance of the other claimed miscellaneous expenses, the claimed $700 would be less than 2 percent of petitioner's adjusted gross income for 1999. Therefore, petitioner would realize no tax benefit therefrom because of the section 67(a) limitation. The third issue is the applicability of the accuracy-related penalties under section 6662(a) determined against petitioner for the 2 years at issue. Petitioner contended that he should be exonerated from these penalties because he relied on his return preparer.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011