Trent Deshawn Allston - Page 9

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          Borough of Manhattan Community College had nothing to do with his           
          job as a campus security guard, conceding that the tuition                  
          expense was not, as claimed on his Schedule A, an unreimbursed              
          employee business expense.  See Evans v. Commissioner, T.C. Memo.           
          1974-267 (employee must show the relationship between the                   
          expenditures and the employment), affd. 557 F.2d 1095 (5th Cir.             
          1977).                                                                      
               With regard to the subscriptions expense, petitioner                   
          testified:  “I have no idea what that is” and conceded that he              
          was not entitled to the $1,987 deduction.                                   
               As noted earlier, petitioner also claimed charitable                   
          contributions for the following:  (1) By cash or check in the               
          amount of $3,860, and (2) other than by cash or check in the                
          amount of $500.  These contributions were disallowed for lack of            
          substantiation.                                                             
               With respect to charitable contributions, section 170 allows           
          a deduction for charitable contributions during the taxable year            
          if verified as provided by the regulations.  Sec. 170(a)(1).  No            
          deduction is allowed for any contribution of $250 or more unless            
          the taxpayer substantiates the contribution by a contemporaneous            
          written acknowledgment of the contribution by the qualified donee           
          organization.  Sec. 170(f)(8)(A).  The standards for record                 
          keeping and return requirements for deductions for charitable               
          contributions are set forth in section 1.170A-13, Income Tax                






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