- 2 -
Respondent determined a deficiency of $7,9772 in petitioners’
2000 Federal income tax and an accuracy-related penalty under
section 6662 of $1,595 that resulted from respondent disallowing
certain of the $26,3563 of expenses petitioners claimed were
ordinary and necessary business expenses under section 162(a)
regarding petitioner Penny Garcia’s (Mrs. Garcia) employment as a
high school English teacher and for petitioner Rodolfo Garcia’s
(Mr. Garcia) employment as a high school golf coach. The parties
filed a stipulation of settled issues in which respondent
conceded additional amounts beyond the expenses respondent
allowed in the statutory notice of deficiency. After these
concessions,4 the issues for decision are:
(1) Whether Mrs. Garcia’s claimed expenses of $2,657 for
movies, theater tickets, videos, supplies, film and film
developing, books, drycleaning, periodicals, gifts, and travel
qualify as ordinary and necessary business expenses under section
162(a). We hold they do not.
2All dollar amounts are rounded to the nearest dollar.
3Petitioners claimed the $26,356 as employee business
expenses before application of the 2-percent limitation in sec.
67. All dollar amounts of the expenses petitioners claimed are
without regard to the 2-percent limitation.
4The agreed adjustments result in a deficiency of $3,791.
The remaining adjustments still in dispute total $4,467. If we
hold in favor of respondent on all these amounts, there will be a
deficiency of $5,051.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011