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The only evidence presented by petitioner in support of her
entitlement to the dependency exemption deduction was an
insurance profile from a Revco pharmacy in Atlanta, which
revealed that Ms. Ofori was 30 years old during the 1993 tax year
and that a total of $247.15 was paid on five occasions for
medication for Ms. Ofori during 1993.
Petitioner performed her critical care nursing in hospital
intensive care or coronary care units and occasionally in homes.
The hospitals were located various distances from Atlanta, in
Rockdale County, Henry County, and Savannah, Georgia. Petitioner
generally used a Jaguar automobile that she acquired in 1992 to
travel to the long-distance hospital jobs. For her school nurse
job or for nearby critical care nursing jobs, she used a smaller
automobile. She had some records of expenses pertaining to a
1979 Toyota Corolla and a 1992 Acura Vigor in addition to the
Jaguar. Although she claimed to have kept records of her mileage
for the agencies for which she worked, she did not produce such
records at trial. Petitioner maintained and offered into
evidence some expense records of insurance premiums and
automobile maintenance expenses in the form of duplicate and
canceled checks. However, these records did not chronicle
petitioner’s vehicle expenses with respect to these automobiles.
Petitioner did not maintain a log reflecting the days, times,
places, and purposes for which she used her vehicles.
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