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allowance from the city for this purpose, which approximated the
cost of three pairs of firefighter uniform pants and one uniform
shirt, but other expenses were out of pocket. Neither the police
nor the firefighter uniform was suitable for off-duty use, and in
fact such use was prohibited.
Petitioner attended church regularly during the year at
issue. Sometimes he would attend his father’s church and other
times his grandfather’s, but he contributed to both churches. He
made weekly payments using offering envelopes provided by the
churches. He put both cash and checks into these envelopes.
Petitioner also made a contribution by cash or check to the
Salvation Army during the year at issue.
On his 2001 Federal income tax return, which was self-
prepared, petitioner reported $64,561 in wage income. On
Schedule A, Itemized Deductions, he claimed a deduction for
$6,600 in unreimbursed employee expenses.4 He also claimed a
charitable contributions deduction of $6,045. Respondent
disallowed the charitable contributions and miscellaneous
employee expenses deductions for lack of substantiation.
With respect to the unreimbursed employee expenses, section
162 allows a deduction for ordinary and necessary expenses that
4 The claimed expenses yielded a deduction of $5,309
after the application of the 2-percent limitation under sec.
67(a).
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Last modified: May 25, 2011