Melinda D. Rivera - Page 16

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          262, however, expressly provides that no deduction shall be                 
          allowed for personal, living, or family expenses.                           
               The parties stipulated various copies of petitioner's                  
          receipts, organized into the following categories:  (1) Parking;            
          (2) dry cleaning; (3) shopping; (4) postage; (5) parking and                
          taxis; (6) Staples and Kinko's; (7) meals; (8) Jiffy Lube; (9)              
          cellular telephone; (10) telephone; (11) Office Max; (12)                   
          insurance; (13) vehicle registration; (14) Unocal (auto repair);            
          and (15) an airline ticket and receipt.  It is not apparent how,            
          or if, the expenses relate to petitioner's employment.                      
               Petitioner's receipts included expenditures for personal dry           
          cleaning, clothes, bicycle equipment, haircuts, and groceries.              
          She admitted that she did not keep any records as to her claimed            
          meals and travel expenses.  Respondent's counsel elicited                   
          testimony from petitioner which demonstrated that petitioner was            
          unable to identify a business purpose for any of the expenses she           
          claimed as deductions.                                                      
               Petitioner testified that she put all her receipts in a box            
          and let her accountant sort them out.  Petitioner's accountant              
          admitted at trial that he mistakenly included in petitioner's               
          deductions expenses that were not deductible and that he agreed             
          with some of respondent's adjustments.                                      

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