- 5 - established that he has complied with the requirements of section 7491(a). Itemized Deductions Respondent determined that petitioner is not entitled to $243 of the $34,881 claimed as total itemized deductions on his 2000 income tax return. This determination was made pursuant to section 67, which provides that “miscellaneous itemized deductions for any taxable year shall be allowed only to the extent that the aggregate of such deductions exceeds 2 percent of adjusted gross income.” Sec. 67(a). On the 2000 income tax return, petitioner claimed miscellaneous itemized deductions of $34,663 before the section 67 reduction. Petitioner’s adjusted gross income for the 2000 taxable year increased from $50,921 to $63,059, the difference being solely attributable to the additional wages of $12,138 that petitioner failed to report on the 2000 income tax return.3 Because of this difference, the 2- percent floor on miscellaneous itemized deductions under section 67 was “raised” by $243. We conclude that respondent has correctly computed this adjustment. We note that respondent’s determination with respect to itemized deductions was based upon the 2000 income tax return and not the amended return. While petitioner has claimed additional 3 As indicated, petitioner reported this amount on his amended return.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011