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visiting the sick. Petitioner does not accept compensation for
his ministerial duties, except for $10 per year, which he does
not report as income.2 For 2000 and 2001, petitioners included
with their Federal income tax returns a Schedule C, Profit or
Loss From Business, that reported that petitioner was a self-
employed minister of the Gospel. During 2000 and 2001,
petitioners’ Federal income tax returns reported no income from
petitioner’s ministerial activities.
For each of the years 2000 and 2001, petitioners claimed
$33,547 of Schedule C deductions for petitioner’s ministerial
activities. Those deductions consisted of $30,752 for mileage,
$945 for nonovernight travel expenses, $600 for meals, and $1,250
for overnight travel expenses. Petitioner’s 2000 and 2001
Federal income tax returns also claimed on Schedule A, Itemized
Deductions, deductions for personal property tax, student loan
interest, noncash charitable contributions, tuition, and job-
related mileage. During respondent’s audit of petitioners’ 2000
and 2001 Federal income tax returns, petitioners did not meet
with respondent’s revenue agent and did not substantiate any of
the deductions. Petitioners informed the revenue agent by a
letter that they had no substantiation for 2000 and 2001 because
their records had been stolen from a storage facility.
Petitioners enclosed with the letter (1) an unsigned, undated,
2 The record does not reveal who pays the $10 to petitioner.
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Last modified: November 10, 2007