Lawrence K. and Ruth L. Harrell - Page 3

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              Respondent determined a deficiency of $8,866 in petitioners’            
         2002 Federal income tax.  The issues for decision are:  (1) The              
         amount of noncash charitable contribution deductions which                   
         petitioners are entitled to claim on Schedule A, Itemized                    
         Deductions, and; (2) the amount of the excess unreimbursed                   
         employee and other miscellaneous expenses deduction1 to which                
         petitioners are entitled.                                                    
                                     Background                                       
              Some of the facts have been stipulated and are so found.                
         The stipulation of facts and the attached exhibits are                       
         incorporated herein by this reference.  At the time of filing the            
         petition, petitioners resided in Miami, Florida.                             
              Petitioners timely filed a joint Form 1040, U.S. Individual             
         Income Tax Return, for taxable year 2002, in which they claimed              
         as Schedule A deductions medical and dental expenses, charitable             
         contributions, and excess unreimbursed employee and other                    
         miscellaneous expenses.  Respondent determined that the amounts              
         claimed for these latter deductions were overstated and                      
         accordingly sent petitioners a notice of deficiency.  Petitioners            
         timely petitioned this Court.  Petitioners concede, and thus no              


               1The excess unreimbursed employee and other miscellaneous              
          expenses deduction is a Schedule A deduction.  The amount equals            
          the sum of:  (1) Unreimbursed employee expenses--job travel,                
          union dues, job education, etc.; (2) tax preparation fees; and              
          (3) other expenses--investment, safe deposit box, etc., less an             
          amount equal to 2 percent (the 2-percent floor) of the taxpayer’s           
          adjusted gross income.  See sec. 67(a).                                     




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