Benjamin C. Kent - Page 11

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          underlying receipts or supporting documentation for the remaining           
          expenses listed on such vouchers.                                           
               Petitioner claimed a deduction for moving expenses of                  
          $13,660 for 2000.  He presented a receipt relating to the move              
          from Jeffersonville, Indiana, to Philadelphia, Pennsylvania, in             
          the amount of $1,315.  This move was in connection with the                 
          commencement not of work, but of law school, and thus, any costs            
          incurred and associated with this move are not allowed as a                 
          deduction under section 217.                                                
              While petitioner incurred some costs for his three moves,              
          most of his costs did not constitute moving expenses as defined             
          under section 217.  Further, petitioner failed to substantiate              
          his claimed moving expenses with documentary evidence such as               
          vendor receipts, credit card statements, canceled checks, or                
          airline tickets.  Petitioner’s testimony also was not credible.             
          Accordingly, since the record provides no basis for making an               
          estimate, we decline to invoke Cohan v. Commissioner, supra.  We            
          sustain respondent’s determination on this issue.                           
          4.  Itemized Deductions                                                     
               Petitioner claimed itemized deductions for home mortgage               
          interest, unreimbursed employee expenses, and casualty and theft            
          loss.  Because petitioner is not entitled to these itemized                 
          deductions, as we discuss later, and because any remaining                  
          itemized deductions are not in excess of the applicable standard            






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