Trent Deshawn Allston - Page 4

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          which included a Schedule A, Itemized Deductions.  Petitioner               
          reported adjusted gross income of $41,392 and claimed Schedule A            
          itemized deductions of $30,010.  He reported an overpayment of              
          tax for the year at issue and claimed a refund of $4,057.                   
               On Schedule A of his return, petitioner claimed the                    
          following deductions:                                                       
          Line  1   Medical and dental expenses              $6,970                   
          Line  4   Net medical deduction                             3,866           
          Line  5   State and local income taxes              2,965                   
          Line  9     Total taxes                                     2,965           
          Line 15   Gifts by cash or check        3,860                               
          Line 16   Gifts other than by cash or check           500                   
          Line 18     Total gifts to charity                          4,360           
          Line 20   Unreimbursed employee business expenses  19,647                   
          Line 26   Net limited miscellaneous deductions             18,819           
          Line 28     Total itemized deductions                      30,010           

               Petitioner’s return was selected for audit examination.                
          Respondent’s examination division requested documentation to                
          support petitioner’s claimed Schedule A itemized deductions.                
          Petitioner did not provide the requested documentation.  In due             
          course, a notice of deficiency was issued to petitioner for 2002            
          disallowing the $30,010 of Schedule A itemized deductions for               
          lack of substantiation.                                                     
               Petitioner filed a timely petition with this Court.  He                
          alleged in his petition that he is not liable for the deficiency            
          in tax for 2002 because he relied on the representations of his             
          return preparer.                                                            

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