Robert A. White - Page 20




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               Accounting Fees                                                        
               Petitioner claimed a deduction in 2003 of $360 for                     
          accounting fees as an unreimbursed employee business expense.10             
          Petitioner testified that he paid his return preparer in cash.              
          He did not produce any receipts.                                            
               It is apparent from the evidence that petitioner paid to               
          have his 2003 Federal income tax return prepared.11  We conclude            
          that petitioner is entitled to a deduction for tax preparation              
          expenses paid in 2003 in the amount claimed, $360.                          
               Computer                                                               
               Petitioner claimed a deduction of $2,285 for a computer but            
          did not produce any receipts or other records to support the                
          deduction.  Computers are listed property, subject to the strict            
          substantiation requirements of section 274(d).  Secs. 274(d),               
          280F(d)(4)(A)(iv).  Accordingly, we may not estimate an allowable           
          deduction for petitioner’s claimed computer expense.                        


               10 Petitioner testified that he paid this amount to his                
          return preparer for 2003.  The record does not indicate why                 
          petitioner included the accounting fees expense with his                    
          unreimbursed employee business expenses on line 20 of Schedule A,           
          Itemized Deductions, rather than on line 21, which is labeled Tax           
          Preparation Fees.                                                           
               11 Petitioner’s 2003 return includes the name of                       
          petitioner’s return preparer, as well as the preparer’s Social              
          Security number or paid preparer tax identification number, the             
          name and address of the firm petitioner used, JD Tax Accounting             
          Services, and the phone number and employer identification number           
          of that firm.                                                               






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Last modified: March 27, 2008