- 9 - Petitioners presented no evidence that they purchased any clothing or shoes that were used by petitioner in his employment that was not adaptable to personal use. The Court recognizes that petitioner was required to wear at work a "bunny", an apparel over his regular clothing, which more than likely would not be suitable for ordinary wear. However, petitioner presented no evidence that he was required to purchase or did in fact purchase such clothing. The inference from the record is that such clothing was provided by petitioner's employer. On this record, petitioners have not established their entitlement to a deduction for unreimbursed employee expenses. The concessions by respondent relate to tax preparation fees, subject to the limitations of section 67(a). Respondent, therefore, is sustained in the disallowance of the itemized deductions at issue, except as to the amounts allowed by the Court and respondent's concessions. The second issue is whether petitioners should be held liable for the section 6662(a) penalties. Petitioners contend they should be absolved of liability for such penalties because they relied on the representations of their return preparer, Mr. Beltran. Section 6662(a) provides for an accuracy-related penalty equal to 20 percent of any portion of an underpayment of tax required to be shown on the return that is attributable to thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011