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limitation, an $8,937 itemized deduction for home mortgage
interest, and a $50 charitable contribution deduction for a
contribution to United Way deducted from Mr. Jackson’s pay from
UPS. Thereupon, petitioners claimed additional medical expense
deductions allegedly not included in the amount reported on their
tax return. During a meeting with respondent’s counsel and at
trial, with respect to the disallowed charitable contributions
deductions, petitioners presented documents generated by
themselves and alleged receipts that were illegible, incomplete,
and some of which had been altered.
The mortgage interest remaining in dispute consists of
$5,800 in points withheld by the lender from a refinanced
mortgage loan obtained by petitioners during 2002. After
conceding that such points should be amortized over the life of
the loan, see sec. 461(g), Ms. Jackson contended at trial that
$6,779.58 of the loan proceeds was used for business purposes and
was therefore deductible on Schedule C.
Mr. Jackson did not appear at trial. In support of the
claimed $350 “small tools” deduction on Schedule A of their 2002
return, Ms. Jackson claimed that the deduction was really for
Mr. Jackson’s steel-toed safety shoes required by UPS. She
presented copies of receipts on which an unidentified person had
written “work shoes”. One of the receipts, however, reflected
hiking boots. Another receipt was for “corporate oxford”. A
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Last modified: May 25, 2011