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1998 1999
Unreimbursed employee expenses
(before the sec. 67(a)
limitation) $13,788 $11,110
Tax preparation fees 500 1,200
Totals $14,288 $12,310
These amounts were disallowed in the notice of deficiency. At
trial, respondent conceded petitioners' entitlement to
deductions, subject to the section 67(a) limitation, of $65 and
$1,220, respectively, for 1998 and 1999 for tax preparation fees.
The unreimbursed employee expenses relate to petitioner's
use of his vehicle, both locally and away from home, in
connection with his employment, a home computer used in
connection with his employment, and special clothing required at
work. Petitioners also included as part of their vehicle
expense, the mileage for use of their vehicle in connection with
their charitable contributions.
Petitioners presented no documentation that would satisfy
the requirements for deduction of travel expenses away from home,
including meals and lodging. To deduct such expenses, section
162(a)(2) requires substantiation of the amounts claimed by
adequate records or by other sufficient evidence corroborating
the claimed expenses pursuant to section 274(d). Sec. l.274-
5T(a)(l), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6,
1985). To meet the adequate records requirements of section
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