Florence C. Blankson - Page 8




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               On her Federal income tax returns for the years at issue,              
          petitioner claimed deductions for expenses relating to her                  
          employment as a nurse on Schedule A.  With respect to her self-             
          employed activity as a critical care nurse, petitioner claimed              
          expenses relating to that activity on Schedule C.  In the notices           
          of deficiency, respondent made some adjustments shifting some of            
          the expenses between the Schedules A and C and, additionally,               
          disallowing some of the expenses.  Petitioner’s objections are              
          directed to the disallowed expenses rather than the shifting of             
          expenses between the two schedules.                                         
               In 1996, petitioner’s Acura automobile was damaged in an               
          accident.  While it was being repaired, she drove a rented car              
          provided by her insurance company.  The rental car was stolen,              
          along with equipment in the car that petitioner used in her                 
          critical care nursing activity.  The loss of the equipment was              
          not covered by insurance.  Petitioner claimed a casualty loss               
          deduction of $4,500 on her 1996 income tax return, Schedule 4684,           
          Casualty Loss, pursuant to section 165(c)(3) but realized no tax            
          benefit because the amount claimed was less than 10 percent of              
          her adjusted gross income.  Sec. 165(h)(2).  Petitioner presented           
          a list of the stolen equipment at trial, which she valued at                











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