- 8 - determination of value is based on two appraisals by qualified real estate appraisers--one for $85,000 and the other for $84,000. Petitioners have offered no evidence that these appraisals do not reflect the fair market value of the property, and we sustain respondent’s determination. 2. 1997 and 1988 Miscellaneous Deductions Petitioners contest the disallowance of only two of the purported deductions--vehicle and educational expenses. With regard to the vehicle expenses, these expenses, as we understand, arise from transportation to and from petitioner’s National Guard drills, and, as such, are expenses incurred for commuting to and from work. Such expenses are not deductible. See Commissioner v. Flowers, 326 U.S. 465 (1946). With regard to the deductions for educational expenses, generally, expenses of obtaining an undergraduate degree are considered personal expenses and, as such, are not deductible. Sec. 262; see Baker v. Commissioner, 51 T.C. 243, 248 (1968). The regulations, however, provide that the expenses are deductible if the education “Meets the express requirements of the individual’s employer, or the requirements of applicable law or regulations, imposed as a condition to the retention by the individual of an established employment relationship, status, or rate of compensation.” Sec. 1.162-5(a)(2), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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