Benjamin O. & Linda L. Agbaniyaka - Page 5




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          JOURNALS DUES”.  As required by section 67(a), petitioners                  
          reduced those expenses by two percent of their adjusted gross               
          income (i.e., by $1,631).  In determining the taxable income                
          reported in their 2001 return, petitioners deducted the balance             
          (i.e., $3,161), as well as the other itemized deductions claimed            
          in the 2001 Schedule A that were not subject to the two-percent             
          floor imposed by section 67(a).                                             
               In the 2002 Schedule A, petitioners claimed $2,300 of                  
          unreimbursed employee expenses, which they identified in that               
          schedule as “EXPENSES”.  As required by section 67(a), petition-            
          ers reduced those expenses by two percent of their adjusted gross           
          income (i.e., by $1,488).  In determining the taxable income                
          reported in their 2002 return, petitioners deducted the balance             
          (i.e., $812), as well as the other itemized deductions claimed in           
          the 2002 Schedule A that were not subject to the two-percent                
          floor imposed by section 67(a).                                             
               In the 2003 Schedule A, petitioners claimed $2,300 of                  
          unreimbursed employee expenses, which they identified in that               
          schedule as “UNION DUES ACCOUNTING JOU”.  As required by section            
          67(a), petitioners reduced those expenses by two percent of their           
          adjusted gross income (i.e., by $1,716).  In determining the                
          taxable income reported in their 2002 return, petitioners de-               
          ducted the balance (i.e., $584), as well as the other itemized              
          deductions claimed in the 2003 Schedule A that were not subject             







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