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Respondent determined a deficiency of $2,409 in petitioner’s
2001 Federal income tax. The issue for decision is whether
petitioner is entitled to itemized deductions for unreimbursed
employee expenses and other miscellaneous deductions.
Alternatively, if petitioner is not entitled to deduct the
claimed other miscellaneous deductions as other miscellaneous
deductions, the Court must decide whether such expenses are
deductible as medical expenses.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioner is a citizen of and a resident of Windsor, Ontario,
Canada. She is employed in the United States at Detroit,
Michigan.
Petitioner is a registered nurse and, during the year at
issue, was employed by a hospital in Detroit. Petitioner also
worked for a home health care agency and performed certain
medical services by visiting patients at home. Those services
were performed in the Detroit metropolitan area. Petitioner was
an employee in both endeavors and received Forms W-2, Wage and
Tax Statement, from her employers for the year 2001. The income
from both sources was reported on petitioner’s Federal income tax
return for 2001, and none of that income is at issue.2 The
2In the notice of deficiency, there was one income
adjustment of $264, which petitioner reported on her return as
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