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be entered is not reviewable by any other court, and this opinion
shall not be treated as precedent for any other case.
Respondent determined deficiencies in petitioner’s Federal
income tax of $2,189 for 2003 and $2,441 for 2004. After
concessions,2 we must decide whether petitioner is entitled to
claim the remaining miscellaneous deductions in dispute.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. When the petition was filed,
petitioner resided in Irvington, New Jersey.
Petitioner was employed as a system administrator for Medco
Health, L.L.C. (Medco), in 2003 and 2004. Petitioner worked
primarily in Medco’s Parsippany, New Jersey, office but sometimes
worked in Medco’s Franklin Lake, New Jersey, office in 2003 and
2004. She worked in Franklin Lake in April, June, and September
2 Petitioner claimed deductions on Schedules A, Itemized
Deductions, for charitable contributions of $1,717 in 2003 and
$1,705 in 2004. Respondent disallowed the $245 noncash portions
of these claimed charitable contributions for both 2003 and 2004.
Petitioner subsequently substantiated greater charitable
contributions than she had originally claimed on her returns, and
respondent conceded that petitioner was entitled to deductions of
$3,380 for 2003 and $3,900 for 2004 unless the standard deduction
is more advantageous. Petitioner also provided documentation to
substantiate that she paid union dues of $315.20 in 2003 and
$391.80 in 2004 and tax preparation fees of $150 in both 2003 and
2004. Respondent concedes that the union dues expenses and the
tax preparation fees are deductible, but only to the extent they
exceed 2 percent of petitioner’s adjusted gross income. See
infra note 3.
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