Akin Falodun - Page 4




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               In 2003, the taxable year in issue, petitioner was employed            
          by Hughes Network Systems, Inc. (Hughes), of Germantown,                    
          Maryland, on a full-time basis, working Monday through Friday               
          from 9 a.m. to 5 p.m.  In addition, petitioner “did some private            
          tutoring as well”, working some evenings and weekends.                      
               At year’s end, petitioner received a Form W-2, Wage and Tax            
          Statement, from Hughes reporting wages paid of $43,563 and a Form           
          1099-MISC, Miscellaneous Income, from Consolidated Education                
          Resources, LLC of Manassas, Virginia, reporting nonemployee                 
          income of $6,215.                                                           
          Petitioner’s Return                                                         
               Petitioner timely filed a Federal income tax return for                
          2003.  On his return, petitioner reported adjusted gross income             
          of $52,587, consisting principally of wages of $43,563 and                  
          business income of $6,215.  On his return, petitioner listed his            
          occupation as “engineer”.                                                   
               Petitioner itemized his deductions, attaching to his return            
          a Schedule A, Itemized Deductions, in support thereof.                      
          Petitioner claimed total itemized deductions of $35,822, which              
          included charitable contributions of $12,921 and unreimbursed               
          employee expenses of $10,348.                                               
          Charitable Contributions                                                    
               On his return, petitioner subdivided total charitable                  
          contributions as follows:                                                   







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