- 3 -
Starting in June 2000, and at all relevant times, petitioner
was employed as an investment banker with Goldman Sachs in New
York, New York. Petitioner’s 2002 return shows her adjusted
gross income as $114,819. According to petitioner, her income
for that year represented a temporary, albeit significant drop in
her usual annual income due to the status of the economy at the
time.2
Petitioner describes herself as an “impulsive buyer” whose
annual expenditures for clothing and shoes might be deemed by
some to be rather extravagant.3 Furthermore, it appears that her
wardrobe is constantly changing. According to petitioner, she
routinely purchases designer clothing and shoes, wears the items
once or twice, and then donates them to an upscale thrift shop in
New York, New York. Despite the fact that her 2002 income was
substantially less than usual, petitioner claims not to have
modified that routine during that year.
Petitioner’s timely filed 2002 Federal income tax return
includes a Schedule A, Itemized Deductions, on which a $55,764
2 For example, petitioner’s 2003 Federal income tax return shows
adjusted gross income of $192,535 and property gifts to charities
of $133,202.
3 On the basis of her credit card charges, petitioner estimates
that she spent $53,916 on clothing and $9,253 on shoes during the
year in issue.
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