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airline fuel and oil and was messy. He estimated that he worked
approximately 22 days per month.
Petitioner claimed he contributed some items to Goodwill and
made cash contributions to his church in 2003.
Petitioner’s Return
Petitioner claimed certain expenses on Schedule A, Itemized
Deductions, on the return for 2003. Respondent examined the
return and issued petitioner a deficiency notice in which he
disallowed many of the expenses. Of the expenses still in
dispute,3 petitioner assert he is entitled to deduct claimed cash
and noncash charitable contributions as well as unreimbursed
employee business expenses. The unreimbursed employee business
expenses petitioner claimed included expenses for his vehicle,
lodging, and meals while in Milwaukee and Detroit as well as
expenses for Internet access, uniform cleaning, depreciation of
tools, and cellular telephone.
Petitioner timely filed a petition.
OPINION
The parties resolved many of the disputed expenses before
trial. We are asked to determine whether petitioner is entitled
to deduct the remaining expenses. We begin by considering
3Respondent concedes that petitioner is entitled to deduct
State and local taxes, real estate taxes, home mortgage interest,
certain amounts for tools, union dues, and tax preparation fees.
The parties agree that petitioner is entitled to deduct a portion
of his personal property taxes and points.
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