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charges, for which he paid Mr. Christie $5,500. On July 23,
1999, petitioner entered into a plea agreement in which he
pleaded guilty to the criminal charges.
Petitioner timely filed Form 1040, U.S. Individual Income
Tax Return, for his taxable year 1999 (petitioner’s 1999 return).
Petitioner did not include the $1,600 McKendree driving allowance
in total income in his 1999 return.
Petitioner included Schedule A-Itemized Deductions (1999
Schedule A) as part of his 1999 return. In that schedule,
petitioner claimed, inter alia, $12,617 of “Job Expenses and Most
Other Miscellaneous Deductions” (job expenses) prior to the
application of the two-percent floor imposed by section 67(a).
Of that total, petitioner claimed $12,157 as “Unreimbursed
employee expenses”. With respect to those claimed unreimbursed
employee expenses, petitioner, as required, completed Form 2106,
Employee Business Expenses (1999 Form 2106), and included that
form as part of his 1999 return. In the 1999 Form 2106, peti-
tioner claimed the following unreimbursed employee expenses:
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Last modified: November 10, 2007