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In or about October 2002, Mr. Williams left U.S. Foods and
began working for Gold Medal. Gold Medal provided a vehicle and
paid for gasoline, although Mr. Williams occasionally used his
own car for business purposes without reimbursement.
In August 2004, Hurricane Charley struck the east coast of
Florida. Shortly after that, Mr. Williams lost his job with Gold
Medal and remained unemployed for the remainder of 2004.
Hurricane Charley also damaged petitioners’ home and destroyed
many of their records.
Petitioners timely filed joint Federal income tax returns
for the years in issue. On Schedule A, Itemized Deductions,
petitioners claimed deductions totaling $34,616, $30,872, and
$23,172 for 2002, 2003, and 2004, respectively. The claimed
deductions consist of medical and dental expenses, taxes,
contributions, tax preparation fees, and unreimbursed employee
business expenses. Respondent disallowed the claimed itemized
deductions in full and instead allowed petitioners the standard
deduction for each year. Petitioners also claimed education
credits of $2,272 and $3,000 in 2003 and 2004, respectively,
which respondent disallowed in full.
Discussion
I. In General
The Commissioner’s determinations set forth in a notice of
deficiency generally are presumed correct, and the taxpayer bears
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