Samie M. and Nora L. Finch - Page 5

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               During taxable year 2002, petitioner Nora L. Finch was                 
          retired and received Social Security benefits.                              
               Petitioners filed a joint Federal income tax return for 2002           
          which included a Schedule A, Itemized Deductions, a Schedule B,             
          Interest and Ordinary Dividends, and a Schedule E, Supplemental             
          Income and Loss.                                                            
               On their jointly filed 2002 tax return, petitioners reported           
          adjusted gross income of $55,009 and claimed Schedule A itemized            
          deductions of $43,639.                                                      
               On their Schedule A, petitioners claimed the following                 
          deductions, in pertinent part:                                              
                         Itemized Deductions                     Amount               
               Line  1   Medical and dental expenses             $4,344               
               Line  4   Net medical deduction                   219                  
               Line  5   State and local income taxes            1,474                
               Line  8   Other taxes                             262                  
               Line  9   Total taxes                             1,736                
               Line 15   Gifts by cash or check                  5,640                
               Line 18   Total gifts to charity                  5,640                
               Line 20   Unreimbursed employee business expenses 29,288               
               Line 26   Net limited miscellaneous deduction     28,188               
               Line 28   Total itemized deductions               43,639               
               On October 8, 2004, respondent issued petitioners a notice             
          of deficiency for taxable year 2002.  Respondent disallowed                 
          $34,046 of petitioners’ claimed $43,639 Schedule A itemized                 
          deductions for taxable year 2002.  The $34,0464 disallowed by               


          4It appears from adding together the disallowed items that                  
          the total amount disallowed should be $34,047 (rounded to the               
          nearest dollar).                                                            




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