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Respondent determined a deficiency of $1,362 in petitioner’s
2001 Federal income tax. The issue is whether petitioner is
entitled to greater itemized deductions than those allowed by
respondent. Petitioner resided in Philadelphia, Pennsylvania, at
the time she filed the petition.
Background
The facts may be summarized as follows. Petitioner is a
detective with the City of Philadelphia Police Department.
Except for formal occasions, she generally did not wear a
uniform.
On her 2001 Federal income tax return, petitioner claimed a
charitable contribution deduction of $6,197 and a miscellaneous
deduction, before the application of section 67, of $5,422.
Respondent disallowed $1,259 of the charitable contribution
deduction and $3,678 of the miscellaneous deduction. The
following amounts are, in whole or in part, in dispute:2
Uniform cost & laundry $1,875
Work shoes & equipment 1,075
Transportation expenses 1,695
2 Of the miscellaneous deduction claimed, respondent allowed
$1,744. The notice of deficiency does not indicate which items
were allowed in whole or in part. Petitioner also claimed union
dues ($627) and tax preparation fees ($150). Respondent does not
contest these items totaling $777. The general question then is
whether petitioner has established that she is entitled to
miscellaneous deductions in an amount greater than the difference
between the amount allowed ($1,744) and the amount conceded
($777), or $967.
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Last modified: May 25, 2011