Thomas James Allen - Page 6

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          Schedule A Itemized Deductions                                              
               Petitioner claimed the following Itemized deductions:                  
                    Form 2106 vehicle expenses         $4,007                         
                    Tax preparation fees               156                            
                    Tax prep. & tax pubs.              100                            
                    Cont. educ. books                  500                            
                    Uniform/shoes                      1,152                          
                                                       5,915                          
               At trial, petitioner had no memory of the expenses he                  
          deducted for the purchases of continuing education books,                   
          uniforms, and shoes.  He also testified that he prepared and                
          electronically filed his own 1998 return.  No evidence was                  
          submitted to substantiate expenses deducted for tax preparation             
          fees and tax publications.  Finally, petitioner admitted that all           
          employee business expenses incurred by him during his employment            
          with Polygram Manufacturing & Distribution Centers were                     
          reimbursed.  He would not, therefore, be entitled to claim a                
          miscellaneous employee business expense deduction for automobile            
          expenses on Schedule A.  We sustain respondent’s disallowance of            
          the $5,915 claimed as miscellaneous itemized deductions on                  
          Schedule A of his 1998 return.1                                             
          Schedule C Business Expenses                                                
               During the examination of petitioner’s 1998 return, and in             
          particular with regard to Schedule C, respondent allowed                    
          petitioner the following business expenses:                                 


          1         As discussed infra, respondent did allow petitioner to            
          deduct automobile expenses on Schedule C of his 1998 return.                




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