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Respondent determined deficiencies in petitioner’s Federal
income taxes for the years 1998 and 1999 in the amounts of $2,409
and $3,617, respectively. All issues regarding the year 1999
raised in the statutory notice of deficiency mailed to petitioner
on September 5, 2001, have been conceded by petitioner, and we
need address only the issues pertaining to the year 1998.
For the year 1998, we are asked to decide: (1) Whether
petitioner is entitled to claimed job expenses and other
miscellaneous itemized deductions in excess of the $1,105 amount
allowed by respondent, and (2) whether petitioner is entitled to
Schedule C business expense deductions in the amount of $12,747
as claimed on his return, or in the amount of $2,459, as allowed
by respondent in the notice of deficiency.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Charlotte, North Carolina, on the date the petition was filed in
this case.
On Schedule A, Itemized Deductions, of his 1998 return,
petitioner claimed job expenses and other miscellaneous
deductions in the amount of $5,915, subject to the 2-percent
floor on miscellaneous itemized deductions in the amount of $510.
Upon auditing petitioner’s return, respondent disallowed the
amount claimed. Respondent also determined, however, that
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