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and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Respondent determined a $5,850 deficiency in petitioner’s
2003 Federal income tax and a $1,170 penalty under section
6662(a). The issues for decision are: (1) Whether petitioner is
entitled to a deduction for claimed home office expenses; (2) the
amount, if any, of the excess unreimbursed employee and other
miscellaneous expenses deduction to which petitioner is
entitled;1 (3) whether petitioner is entitled to a deduction
under section 179 with respect to a motor vehicle; (4) the amount
of the deduction for charitable contributions to which petitioner
is entitled; and (5) whether petitioner is liable for a penalty
under section 6662(a).
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
College Station, Texas, at the time he filed the petition.
1The excess unreimbursed employee and other miscellaneous
expenses deduction is claimed on Schedule A, Itemized Deductions.
The amount of the deduction equals the sum of: (1) Unreimbursed
employee expenses--job travel, union dues, job education, etc.;
(2) tax preparation fees; and (3) other expenses--investment,
safe deposit box, etc., less an amount equal to 2 percent (the 2-
percent floor) of the taxpayer’s adjusted gross income. See sec.
67(a).
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Last modified: November 10, 2007