Ibrahim Keita - Page 12

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          established that his use of the vehicle satisfied the                       
          requirements of section 162, the logs he provided listing the               
          business miles he drove do not meet the substantiation                      
          requirements of section 274(d), because petitioner did not                  
          provide the total mileage for all use of the automobile during              
          the taxable period.  Therefore, petitioner’s transportation                 
          expenses do not meet the trade or business requirement of section           
          162, or the substantiation requirements of section 274(d), so he            
          is not entitled to deduct his transportation expenses as Schedule           
          A unreimbursed employee expenses.                                           
               B.   Tax Preparation Fees                                              
               A taxpayer may be allowed a deduction for ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          connection with the determination, collection, or refund of any             
          tax.  Sec. 212(3).  Petitioner claimed a deduction for tax                  
          preparation fees of $375 as a miscellaneous deduction on Schedule           
          A.  At trial, respondent conceded that petitioner was allowed               
          $250 of the claimed deduction, so we do not further address this            
               Petitioner claims that he purchased Turbo Tax software for             
          $125 to prepare his return for tax year 2003, after his taxes               
          were not prepared satisfactorily by a professional tax preparer.            
          Petitioner admitted at trial that he did not know how much Turbo            
          Tax cost and that the $125 was an estimate.  Petitioner presented           

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Last modified: November 10, 2007