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metal worker. These items were normal clothes. Petitioners
introduced copies of 12 receipts totaling $338.58 as
substantiation for purchases of these items. The receipts
indicate that the dollar amounts for all of the items purchased
are generally small, ranging from a low of 50 cents to a high of
$14.99. The receipts do not provide descriptions of the items
purchased or identify the stores from which petitioners purchased
the items.
On their 2002 Form 1040, petitioners claimed medical and
dental expenses of $8,020 on Schedule A, Itemized Deductions,
attached to their return, which resulted in a deduction of $4,963
after application of the limitation in section 213(a). Of the
$8,020 in claimed medical and dental expenses, petitioners
calculated $7,100 as paid for health insurance. Respondent
disallowed the entire $8,020 of claimed expenses in the notice of
deficiency on the grounds that petitioners had not substantiated
payment of the expenses.6
Also on Schedule A, petitioners deducted $11,741 as Mr.
Marple’s unreimbursed job expenses, made up of the following:
Vehicle expenses of $8,879 (24,325 business miles at the standard
mileage rate of 36-1/2 cents per mile); business meals and
entertainment expenses of $399 (after application of the 50-
6 As noted, petitioners submitted to respondent medical
and dental care receipts totaling $920, which respondent has
accepted.
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Last modified: November 10, 2007