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petitioner claimed on Schedule C, Profit or Loss From Business,
under expenses a bad debt deduction of $10,000 for the incident.
That deduction was disallowed by respondent in the notice of
deficiency. Petitioner also deducted Schedule C “other expenses”
of $3,500, which he identified as $1,500 for business meetings
and $2,000 for a cellular telephone. Both items were disallowed
in the notice of deficiency; however, at trial respondent
conceded $579.44 of the phone expenses, leaving $2,920.56 at
issue. The deductions were disallowed for lack of
substantiation.
Finally, in the notice of deficiency, respondent disallowed
Schedule A, Itemized Deductions, amounts claimed by petitioner on
his 2000 and 2001 income tax returns for charitable contributions
of $10,307 and $16,680, respectively. Additionally, petitioner
claimed itemized deductions for home mortgage interest of $6,766
and $8,100, respectively, for 2000 and 2001. These deductions
were also disallowed for lack of substantiation.
With respect to the first issue, the claimed head of
household filing status for the year 2000, section 2(b) defines a
head of household as an individual taxpayer who (1) is not
married at the close of the taxable year and (2) maintains as his
home a household which constitutes the principal place of abode
for more than one-half of the taxable year of a person who is a
dependent of the taxpayer, if the taxpayer is entitled to a
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