Samuel S. and Laura M. Pinkney - Page 5

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          the use of, inter alia, a State, possession of the United States,           
          or any political subdivision of the foregoing.  Sec. 170(c)(1).             
               On their joint 2002 Federal income tax return, petitioners             
          deducted charitable cash contributions of $5,456.  Respondent               
          initially allowed $2,385 of that amount and later conceded an               
          additional $2,825, leaving $246 in dispute.  At trial,                      
          petitioners introduced a copy of a check for $25 to the City of             
          Carson.  The face of the check bears no indication that the $25             
          represents a contribution or gift, and petitioners offered no               
          testimony with respect to this item.  Accordingly, respondent’s             
          determination is sustained to the extent of $246.                           
               B.  Other Expenses                                                     
               Section 162(a) generally allows a deduction for ordinary and           
          necessary business expenses.  To qualify as an allowable                    
          deduction under section 162(a), an item must be:  (1) Paid or               
          incurred during the taxable year; (2) for carrying on any trade             
          or business; (3) an expense; (4) a necessary expense; and (5) an            
          ordinary expense.  Commissioner v. Lincoln Sav. & Loan                      
          Association, 403 U.S. 345, 352 (1971); FMR Corp. & Subs. v.                 
          Commissioner, 110 T.C. 402, 414 (1998).                                     
               Petitioners attached to their return a Schedule C, Profit or           
          Loss From Business, for a business described as real estate                 
          consulting.  Petitioners deducted $29,132 of other expenses on              
          Schedule C, consisting of items such as supplies expense, tax               






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