James L. and Patricia R. Williams - Page 4




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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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