- 7 - section 1.162-5(a), Income Tax Regs., the expenses are not deductible under section 162.3 Respondent’s disallowances of the job expenses deduction and other miscellaneous itemized deductions are sustained. Charitable Contributions Deduction Section 170(a) allows as a deduction any charitable contribution which is made within the taxable year. A charitable contribution is a contribution or gift to or for the use of an organization described in section 170(c). Petitioner claimed a charitable deduction in the amount of $1,300, for payments made to his sister to assist in the care of his ill mother. While we commend petitioner for contributing to the support of his ill mother, those contributions do not qualify for deduction under section 170. Respondent’s disallowance of the charitable contribution deduction is sustained. Section 6662(a) Penalty Respondent determined that the underpayment of tax required to be shown of petitioner’s 2000 return is due to negligence or disregard of rules or regulations. See sec. 6662(a) and (b)(1) and (2). Negligence is defined to include any failure to make a reasonable attempt to comply with the provisions of the Internal Revenue Code. Sec. 6662(c). It is further defined as the 3 We note that respondent did allow petitioner a Lifetime Learning Credit under sec. 25A with respect to his qualified tuition and related expenses for the taxable year 2000.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011