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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.
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