- 23 - disagree. Neither Hughs nor Zima had copies of all of petitioners’ checks and bank statements at any time. Zima saw about 15 checks which he included in the stipulation of facts. Hughs saw 30 to 40 checks, but petitioner did not allow her to copy or keep them. Those statements do not conflict. We conclude that petitioners may not deduct any unreimbursed employee business expenses for Susan Fairey for the years in issue. 2. Petitioner’s Deductions for Employee Business Expenses Petitioners contend that petitioner may deduct unreimbursed employee business expenses for 1999. We disagree. Although petitioner was an employee of TruGreen for a short time in 1999, there is no evidence that he had any unreimbursed employee business expenses in 1999. 3. Charitable Contribution Deductions and Other Itemized Deductions Petitioners have not shown that they are entitled to more charitable contribution deductions or other itemized deductions than respondent allowed. E. Whether Petitioner Is Liable for the Fraud Penalty for 2000 1. Contentions of the Parties and Background Respondent contends that petitioner is liable for the fraud penalty under section 6663 for 2000 because petitioner fraudulently deducted (a) $7,500, which he never paid, in three places on the 2000 return, and (b) $59,727 for legal andPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011