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return and issued petitioners a deficiency notice in which he
disallowed many of the expenses. Of the expenses still in
dispute,2 petitioners assert they are entitled to claimed noncash
charitable contributions as well as unreimbursed employee
business expenses. The unreimbursed employee business expenses
petitioners claimed include expenses for Mr. Farran’s vehicle,
lodging, and meals while in Detroit, Chicago, and Boston as well
as expenses for Internet access, uniform cleaning, tools,
depreciation of tools, personal property taxes, job searching,
supplies, parking, publications, cellular telephone, and
education mileage.
Petitioners timely filed a petition.
OPINION
The parties resolved many of the disputed expenses before
trial. We are asked to determine whether petitioners are
entitled to deduct the remaining expenses. We begin by
considering whether Mr. Farran was away from home when he
incurred expenses for his vehicle, meals, and lodging in Detroit,
Chicago, and Boston.
2Respondent concedes that petitioners are entitled to deduct
State and local taxes, real estate taxes, a portion of personal
property taxes, home mortgage interest, tax preparation fees, a
portion of job search expenses including job search mileage
expenses, job union mileage expenses, certain amounts for tools,
and union dues. Petitioners concede that they are not entitled
to deduct cash contributions to charity and a portion of uniform
cleaning expenses.
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Last modified: November 10, 2007