Michael Gregorian and Yolanda Gregorian a.k.a. Yolanda Trelles - Page 8

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          excessive, (c) the repairs do not care for more than the damage             
          suffered, and (d) the value of the property after the repairs               
          does not as a result of the repairs exceed the value of the                 
          property immediately before the casualty.                                   
               Petitioners’ claim and the basis upon which they make that             
          claim fails to meet the criteria set out above entitling them to            
          a casualty loss deduction.  The Court holds that the damage they            
          sustained did not result from a “closed and completed                       
          transaction”.  The damage occurred over a period of time.                   
          Moreover, if petitioners sustained an allowable casualty loss,              
          petitioners failed to establish the amount of the loss.  The                
          Court, therefore, sustains respondent on this issue.                        
               The second issue is petitioners’ claim to an itemized                  
          deduction for unreimbursed employee expenses in the amount of               
          $22,138 prior to the 2-percent limitation under section 67(a).              
          Petitioners included with their return Form 2106-EZ, Unreimbursed           
          Employee Business Expenses, on which they claimed the following             
          expenses:                                                                   

               Vehicle expenses                             $12,213                   
               Parking fees, tolls, etc.                        725                   
               Travel expenses away from home                 4,250                   
               Business expenses                              2,240                   
               Meals and entertainment                        2,710                   
          Total                                        $22,138                        

          The amount claimed was disallowed in full in the notice of                  
          deficiency.                                                                 





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