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B. Taxes Paid
Petitioner claimed a deduction for State and local taxes
paid of $4,097.60. In his pretrial memorandum, respondent
conceded that, if petitioner’s allowable itemized deductions are
greater than the standard deduction, petitioner is entitled to a
deduction for the taxes paid.
C. Charitable Contributions
Section 170(a)(1) generally authorizes a taxpayer to claim a
deduction for any charitable contribution made during the taxable
year. On Schedule A to his 2001 return, petitioner claimed a
charitable contribution deduction for cash gifts to a church
($690) and for noncash gifts ($820). The only documentation
produced by petitioner was a receipt, purportedly from the
Salvation Army, regarding the noncash contribution. At trial
respondent convincingly proved that the documentation had been
falsified. Consequently, the record contains no credible
evidence substantiating petitioner’s charitable contributions for
2001, and we sustain respondent’s determination.
D. Unreimbursed Employee Business Expenses and Other
Miscellaneous Expense
Section 162(a) authorizes a taxpayer to deduct ordinary and
necessary business expenses paid or incurred during the taxable
year in carrying on a trade or business. An “ordinary” expense
is one incurred in a transaction that commonly or frequently
occurs in the type of business involved. Deputy v. du Pont, 308
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