Benjamin C. Kent - Page 12

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          deduction, petitioner is entitled to the standard deduction for             
          1999 and 2000.                                                              
               a.  Home Mortgage Interest                                             
               Petitioner claimed itemized deductions for home mortgage               
          interest expense of $21,200 for the 1999 taxable year and $20,614           
          for the 2000 taxable year.  Respondent decreased the claimed                
          amount for 1999, allowing a deduction of $3,222, and disallowed             
          the claimed deduction for 2000 in full.                                     
               Mortgage interest is generally deductible under section                
          163(a), subject to the requirements of section 163(h).                      
          Petitioner, however, has not substantiated that he paid mortgage            
          interest expense of any amount in 1999 or 2000.  We therefore               
          sustain respondent’s determination on this issue.  Sec. 6001;               
          sec. 1.6001-1(a), (e), Income Tax Regs.                                     
               b.  Unreimbursed Employee Expenses                                     
               Petitioner claimed a deduction for unreimbursed employee               
          expenses of $1,125 for 1999.                                                
               “It is clear that an individual may be in the trade or                 
          business of being an employee and that ordinary and necessary               
          expenses incurred in that trade or business are deductible under            
          section 162.”  Kurkjian v. Commissioner, 65 T.C. 862, 869 (1976).           
          Petitioner, however, has not provided any evidence to                       
          substantiate either the existence or amount of any unreimbursed             








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