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subcontractor for Comcast. As a subcontractor, Mr. Schubert
traveled to customers’ residences and disconnected the customers’
cable for failure to pay their Comcast bills. Mr. Schubert was
unemployed for the remainder of 2003.
Ms. Moore worked as a real estate agent for Intero Real
Estate Services and as an administrator for Superior Employment,
Inc. Ms. Moore showed properties to clients, transported
transactional documents, and performed other errands in San Jose,
Santa Clara, and Palo Alto, California.
Petitioners timely filed a joint Form 1040, U.S. Individual
Income Tax Return, for 2003. Petitioners reported $55,955 as
compensation for services ($13,687 for Mr. Schubert and $42,268
for Ms. Moore). On petitioners’ Schedule A, Itemized Deductions,
they claimed a $75 deduction for their tax preparation materials
and the following unreimbursed employee expenses:
Category Mr.Schubert Ms. Moore
Vehicle expense 1$12,884 1$12,312
Parking, tolls, 625 550
transportation
Travel expense 1,650 1,300
away from home
Meals and 550 650
entertainment
Business expense 4,725 11,175
Total 220,434 225,987
1 Based on a 36-cent standard mileage rate.
2 Before application of the sec. 67(a) 2-percent floor.
Respondent disallowed petitioners’ deductions for
unreimbursed employee expenses and tax preparation materials.
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Last modified: March 27, 2008