Thomas C. Pride, Sr. - Page 6

                                        - 5 -                                         
          donated property that include the information” listed above.  Id.           


               Petitioner argues that he donated clothes and various                  
          household items to Goodwill, the Salvation Army, and the Boys’              
          Club.  However, petitioner provided no written records concerning           
          any donations and has provided this Court with no method by which           
          to ascertain with a reasonable degree of certainty what he                  
          contributed during 1999.  We sustain respondent’s disallowance of           
          the relevant portion of the charitable contribution deduction.              
          Sec. 170(a)(1); sec. 1.170A-13, Income Tax Regs; see also sec.              
          6001; sec. 1.6001-1(a), (e), Income Tax Regs.                               
               The final deduction in dispute is the deduction for employee           
          business expenses.  Unreimbursed employee business expenses                 
          generally may be deductible under section 162(a).  However, the             
          deduction is a miscellaneous itemized deduction.  Sec. 67(b).  A            
          taxpayer’s miscellaneous itemized deductions are allowed only to            
          the extent by which they exceed 2 percent of the taxpayer’s                 
          adjusted gross income.  Sec. 67(a).  Petitioner argues that he              
          incurred expenses for clothing which he was required to wear to             
          his job; subscriptions to various magazines; union dues; and                
          attendance at work-related seminars.  He estimated that the                 
          magazine subscriptions were “less than $100" and that the union             
          dues were “roughly” between $120 and $140 per year.  The clothing           
          which petitioner was required to wear to work consisted of suits            






Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011