Keith T. and Geraldine A. Bowers - Page 9

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          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.                








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