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apartment during 1999 and also the address listed for Mr.
Wiggins, Dontae’s father. This form indicates that Dontae lived
with both “Natural Parents” and “Legal Guardians”. Petitioner is
indicated as the female head of household.
Petitioner worked as a corrections officer for which she
received $51,078 as wages in 1999. She wore a uniform to work
that she purchased instead of wearing the uniform provided at no
cost to her by her employer, the District of Columbia Department
of Corrections. Petitioner drove to and from work each day, and
paid about $10 per week for parking. Petitioner did not drive
her automobile as part of her job duties. The claimed deductions
for unreimbursed employee expenses include parking tickets
petitioner received while at work and transportation expenses.
Petitioner claimed the following deductions on Schedule A of
her Federal income tax return for 1999:
Gifts to charity (cash or check) $3,640
Gifts to charity (other than in 500
cash or by check)
Unreimbursed employee expenses 2,400
Tax preparation fees 250
Other expenses (care of work wear) 2,500
Respondent denied the deductions in full for failure to
substantiate the amounts claimed.
Discussion
1. Dependency Exemption Deductions
A taxpayer is allowed a deduction for a dependent over half
of whose support is provided by the taxpayer. Secs. 151(c)(1),
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