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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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