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The
following is the text of the Tax Court Case.
T.C.
Memo. 2002-197
UNITED
STATES TAX COURT
PERRY
H. KAY, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE,
Respondent
Docket
No. 10828-00.
Filed
August
8, 2002
.
Emil
R. Sargent, for petitioner.
Portia
N. Rose, for respondent.
MEMORANDUM
FINDINGS OF FACT AND OPINION
GOLDBERG,
Special Trial Judge: Respondent determined a deficiency in
petitioner's Federal income tax for the taxable year 1998 in the
amount of $4,181.50. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect for the year
at issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After
concessions by respondent,<<ENDNOTE 1>> the remaining
issues for decision are (1) whether petitioner is entitled to
deduct certain Schedule C, Profit or Loss From Business, expenses
for the year at issue, and (2) whether petitioner is entitled to a
casualty loss deduction of $5,151.19 for 1998.
FINDINGS
OF FACT
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. At the time the petition was filed,
petitioner resided in
Houston
,
Texas
.
Petitioner
holds a master's degree in music education from the
University
of
North
Texas
.
Petitioner was employed as a full-time band teacher for 31 years,
26 of those years at
Lanier
Middle
School
in
Houston
,
Texas
.
Since retiring from full-time employment, petitioner has taught
band part time. During 1998, petitioner was employed as a
part-time assistant band director for the
North
Forest
Independent
School
District
.
During
1998, petitioner also operated PK Production and Management (PK
Production), a small business providing music entertainment
services. Petitioner managed and played in a band for
compensation. For the year at issue, the band only participated in
four or five paid engagements.
With
respect to PK Production, petitioner claimed that on
January
1, 1998
,
he placed in service a 1995 Dodge Caravan (van), which was
purchased in 1997. During the year at issue, petitioner used the
van to transport musical equipment to and from the band's
engagements. Petitioner testified that during 1998 the van was
used primarily for PK Production business purposes.
On
Schedule C, petitioner claimed various business expense deductions
in the operation of PK Production. Petitioner's claimed expense
deductions that are at issue include: (1) A section 179 expense
deduction of $7,000 for the van; (2) expenses in connection with
the van for business-related travel of $4,182; (3) production and
management fees of $999.20; and (4) music educator and
professional convention expenses of $333.95.
During
1998, petitioner owned a three-bedroom ranch-type house located at
5134
Heatherbrook Drive
,
Houston
,
Texas
.
On
September
11, 1998
,
a rain and wind storm damaged the roof and several rooms of
petitioner's house. Petitioner reported the incident to the State
Farm Insurance Company (State Farm), with whom petitioner
maintained a homeowner's insurance policy during 1998. On
October
12, 1998
,
State Farm settled the claim with petitioner for $857.12. On
October
29, 1998
,
petitioner retained a contractor to replace rotten decking and
install a new roof on petitioner's house. For the year at issue,
petitioner claimed a casualty loss deduction on Schedule A,
Itemized Deductions, of $5,151.19 related to the damage caused by
the storm.
In
the notice of deficiency, respondent disallowed the following: (1)
The entire section 179 expense deduction claimed on Schedule C
because petitioner "did not establish the percentage of
business use" for the van and failed to provide other
supporting information required to substantiate the deduction; (2)
the business-related travel expense for the van claimed on
Schedule C because petitioner failed to provide the supporting
information necessary to establish that the deduction was
"(a) incurred during the taxable year, and (b) an ordinary
and necessary business expense"; (3) expenses claimed on
Schedule C for (a) production and management fees, and (b) music
educator and professional convention expenses because petitioner
did not substantiate that these expenses were paid or incurred
during the taxable year and were "ordinary and
necessary" business expenses; and (4) the entire casualty
loss deduction claimed on Schedule A because petitioner "did
not establish that (a) a casualty or theft occurred, and (b) any
loss was sustained".
OPINION
The
determinations of the Commissioner in a notice of deficiency are
presumed correct, and the burden is on the taxpayer to show that
the determinations are incorrect. Rule 142(a); Welch v. Helvering,
290
U.S.
111, 115 (1933).<<ENDNOTE 2>>
Deductions
are a matter of legislative grace, and the taxpayer bears the
burden of proving the entitlement to any deduction claimed.
INDOPCO, Inc. v. Commissioner, 503
U.S.
79, 84 (1992); New Colonial Ice Co. v. Helvering, 292
U.S.
435, 440 (1934). A taxpayer is required to maintain records
sufficient to establish the amount of his or her income and
deductions. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
1.
SCHEDULE C--BUSINESS EXPENSE DEDUCTIONS
Section
162(a) allows a taxpayer to deduct all ordinary and necessary
business expenses paid or incurred during the taxable year in
carrying on any trade or business. To be "ordinary" the
transaction which gives rise to the expense must be of a common or
frequent occurrence in the type of business involved. Deputy v. Du
Pont, 308
U.S.
488, 495 (1940). To be "necessary" an expense must be
"appropriate and helpful" to the taxpayer's business.
Welch v. Helvering, supra at 113. Additionally, the expenditure
must be "directly connected with or pertaining to the
taxpayer's trade or business". Sec. 1.162-1(a), Income Tax
Regs.
Generally,
if a claimed business expense is deductible, but the taxpayer is
unable to fully substantiate it, the Court is permitted to make as
close an approximation as it can, bearing heavily against the
taxpayer whose inexactitude is of his or her own making. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). The estimate
must have a reasonable evidentiary basis. Vanicek v. Commissioner,
85 T.C. 731, 743 (1985). However, section 274 supersedes the
doctrine of Cohan v. Commissioner, supra, sec. 1.274-5T(a),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (
Nov.
6, 1985
),
and requires strict substantiation of expenses for travel, meals
and entertainment, and gifts, and with respect to any listed
property as defined in section 280F(d)(4). Sec. 274(d). Listed
property includes any passenger automobile or any other property
used as a means of transportation. Sec. 280F(d)(4)(A)(i) and (ii).
A
taxpayer is required by section 274(d) to substantiate a claimed
expense by adequate records or by sufficient evidence
corroborating the taxpayer's own statement establishing the
amount, time, place, and business purpose of the expense. Sec.
274(d). Even if such an expense would otherwise be deductible, the
deduction may still be denied if there is insufficient
substantiation to support it. Sec. 1.274-5T(a), Temporary Income
Tax Regs., supra.
A.
Vehicle-Related Expenses
On
Schedule C, petitioner claimed both a section 179 expense
deduction for $7,000 and business-related vehicle expenses of
$4,182 on the same vehicle. It is unclear from the record whether
petitioner used actual expenses or the standard mileage rate to
calculate the claimed deduction of $4,182. No evidence was
introduced to substantiate any actual expenses incurred and the
number of business miles claimed on Schedule C multiplied by the
1998 standard mileage rate is not equal to the amount of the
claimed deduction.<<ENDNOTE 3>>
Actual
expenses related to the business use of a vehicle are deductible
under section 274, if substantiated. If actual expenses were used
to determine the business-related vehicle expenses claimed,
petitioner, having failed to substantiate any such expense, is not
entitled to the business-related vehicle expenses claimed. See
sec. 274(d).
Alternatively,
a taxpayer may choose to use the business standard mileage rate in
lieu of the actual automobile expenses. Nash v. Commissioner, 60
T.C. 503, 520 (1973); Parker v. Commissioner, T.C. Memo. 1993-15;
Rev. Proc. 97-58, 1997-2 C.B. 587. However, the business standard
mileage rate may not be used to compute deductible expenses if the
taxpayer has claimed a section 179 expense deduction on the same
vehicle. Rev. Proc. 97-58, 1997-2 C.B. 587. Thus, petitioner may
not claim deductions on the van for both the section 179 expense
and the standard mileage rate. Assuming petitioner could
substantiate entitlement to a deduction for both expenses,
petitioner would be limited to either the section 179 expense
deduction or the standard mileage rate deduction, but not both.
i.
Section 179 Expense
Petitioner
claimed a section 179 expense deduction of $7,000 on Schedule C
for the year at issue. For the 1998 taxable year, section 179
allows a taxpayer to elect to expense, as a deduction for the year
in which the property was placed in service, up to $18,500 of the
cost of certain property acquired for use in the active conduct of
a trade or business. Sec. 179(a), (b), (d). "The term 'placed
in service' means the time that property is first placed by the
taxpayer in a condition or state of readiness and availability for
a specifically assigned function, whether for use in a trade or
business, for the production of income, in a tax-exempt activity,
or in a personal activity." Sec. 1.179-4(e), Income Tax Regs.
Petitioner
claimed on Form 4562, Depreciation and Amortization, that the van
was placed in service on
January
1, 1998
.
However, petitioner presented an invoice at trial for the purchase
of the van dated
March
6, 1997
.
Further, petitioner testified that the van was driven for personal
use "part of the time." Therefore, the only evidence
presented on this point indicates that the van was first placed in
service in a personal activity in 1997. The section 179 expense is
allowed as a deduction only in the year the property is placed in
service. See sec. 179(a); Hendrix v. Commissioner, T.C. Memo.
1990-221; sec. 1.179-4(e), Income Tax Regs. Accordingly,
petitioner is not entitled to the section 179 expense deduction
claimed on the van in 1998.
ii.
Business Standard Mileage Rate Expense
Since
we found above that petitioner is not entitled to a section 179
expense deduction, petitioner may use the standard mileage rate to
calculate the business-related vehicle expenses on the van, if
substantiated.
The
business standard mileage rate in lieu of operating and fixed
costs allows the taxpayer to deduct an amount determined by
multiplying the business standard mileage rate for the year at
issue by the number of miles driven for business purposes. Rev.
Proc. 97-58, 1997-2 C.B. 587. The standard mileage rate for 1998
was 32.5 cents per mile.
Id.
Petitioner
reported 12,370 miles driven for business purposes on Schedule C
for the year at issue. Petitioner claimed a vehicle expense
deduction of $4,182. At trial, petitioner presented no evidence to
substantiate the business mileage reported or the vehicle expense
claimed. Petitioner testified that he did not "keep" his
business mileage. Petitioner's witness, Alonza O. C. Sargent,
testified that petitioner did maintain a mileage log, but no such
log was introduced at trial.
As
stated above, section 274 requires strict substantiation for
deductions claimed for transportation in a passenger car.
Petitioner is required to provide a mileage log or other
corroborative evidence sufficient to establish the amount, time,
place, and business purpose of the expense. Sec. 274(d). At trial,
petitioner failed to provide any corroborating evidence whatsoever
to satisfy the section 274 substantiation requirements.
Based
on a partial mileage log reviewed by respondent during an
examination prior to trial, respondent conceded that petitioner
was entitled to 5,742 business miles.<<ENDNOTE 4>>
Applying the standard mileage rate for 1998, respondent concedes
that petitioner is entitled to a vehicle expense deduction of
$1,866 for the year at issue. Although petitioner did not
substantiate entitlement to a deduction in any amount at trial, we
shall not disturb the respondent's concession. Accordingly,
petitioner is entitled to a vehicle expense deduction of $1,866
for the year at issue.
B.
Production and Management Fees
Petitioner
claimed a business expense deduction for production and management
fees in the amount of $999.20 on Schedule C for the year at issue.
At trial, petitioner presented documentation substantiating
$486.70 of the amount claimed. We are satisfied that the
substantiated items are ordinary and necessary business expenses
directly connected with petitioner's Schedule C business, as
required under section 162(a) and the regulations thereunder.
Petitioner
presented absolutely no evidence, either documentary or
testimonial, to substantiate the additional $512.50 of expenses
claimed. Petitioner is not entitled to a deduction for business
expenses that are completely unsubstantiated. Ronnen v.
Commissioner, 90 T.C. 74, 102 (1988).
Therefore,
petitioner is entitled to a Schedule C business expense deduction
only for production and management fees in the amount of $486.70
for the year at issue.
C.
Music Educator and Professional Convention Expense
Petitioner
claimed a business expense deduction for music educator and
professional convention expenses in the amount of $1,381.44 on
Schedule C for the year at issue. After respondent's concession
allowing a deduction of $1,047.49 for expenses related to the New
York City Convention, only $333.95 of the total claimed expense
remains at issue. The majority of the remaining expenses was
incurred in connection with two other conventions attended by
petitioner during 1998.
In
February 1998, petitioner attended the Texas Music Educators
Association Convention in
San
Antonio
,
Texas
.
Petitioner claimed business expenses relating to the convention in
the amount of $113.10.
In
July 1998, petitioner attended the Texas Bandmasters Association
Convention in
San
Antonio
,
Texas
.
Petitioner claimed business expenses relating to the convention in
the amount of $155.79.
Respondent
asserts that the expenses incurred with respect to both
San
Antonio
,
Texas
,
conventions relate to petitioner's employment as an assistant band
director and not to PK Production.
At
trial, petitioner testified that the claimed expenses relating to
the conventions pertained to both PK Production and his employment
as a band educator. However, petitioner failed to allocate the
expenses accordingly, claiming the expenses entirely as business
expenses on Schedule C.
Petitioner
further testified that the conventions were related to his
Schedule C business because the conventions (1) offered seminars
and workshops that benefited petitioner as a musician, (2) were
attended by other bands' members who shared "some different
techniques and various things *** that would benefit any
professional musician", and (3) provided exhibits featuring
manufacturers and distributors selling professional equipment.
While
petitioner may have attended seminars and engaged in conversations
with various individuals about techniques and equipment at the
conventions, we believe that these activities are not
"directly connected with or pertaining to" petitioner's
Schedule C business. Sec. 1.162-1(a), Income Tax Regs. The fact
that petitioner may have derived some incidental or indirect
benefit to his business by attending the conventions is not
sufficient to satisfy the requirements of section 162(a). See
Henry v. Commissioner, 36 T.C. 879, 884 (1961).
The
registration forms presented by petitioner at trial clearly
establish that the conventions were organized by educational
associations for the benefit of music educators.
The
Texas
Music Educators Association Convention Membership Application
requested information pertaining to the applicant's teaching
division and level. On the application, petitioner selected that
he taught band at the middle school/junior high school level.
Petitioner
completed the Texas Bandmasters Association Convention
Registration Form indicating that he was affiliated with the
Oak
Village
Middle
School
.
Further, petitioner only selected the middle school option when
asked to select the appropriate options that applied to the
applicant.
Petitioner
unequivocally completed both applications as an educator, making
no mention whatsoever of PK Production. Petitioner testified that
he had a choice of associating himself with the school or PK
Production when completing the applications, yet petitioner chose
to affiliate himself with the school on both occasions.
It
appears to the Court that from the evidence presented that
petitioner attended both
San
Antonio
,
Texas
,
conventions primarily in his capacity as an assistant band
director. The record is clear that petitioner has failed to
establish that the expenses associated with the
San
Antonio
,
Texas
,
conventions claimed on Schedule C were ordinary and necessary
expenses directly related to PK Production. See sec. 162(a); sec.
1.162-1(a), Income Tax Regs.
Petitioner
presented absolutely no evidence, either documentary or
testimonial, to substantiate the additional $65.06 of expenses
claimed as music educator and professional convention expenses.
Petitioner is not entitled to a deduction for business expenses
that are completely unsubstantiated. Ronnen v. Commissioner,
supra.
Therefore,
petitioner is not entitled to a Schedule C deduction in any amount
for the $333.95 of expense claimed as music educator and
professional convention expenses.
However,
since we found that petitioner incurred convention expenses of
$268.89 relating to his employment as an assistant band director,
we must determine whether these expenses are deductible as
unreimbursed employee expenses on Schedule A, Itemized Deductions,
subject to the 2-percent floor under section 67(a).
A
taxpayer is not allowed an unreimbursed employee expense deduction
if the employer maintains a reimbursement plan and the employee
fails to seek reimbursement for work-related expenses. Leamy v.
Commissioner, 85 T.C. 798, 810 (1985).
There
is absolutely nothing in the record to indicate whether
petitioner's employer maintained a reimbursement plan in the year
at issue, nor has petitioner provided any evidence to establish
that he sought reimbursement for the convention expenses.
Accordingly, petitioner is not entitled to claim unreimbursed
employee expenses on Schedule A for the expenses related to either
of the
San
Antonio
,
Texas
,
conventions.<<ENDNOTE 5>>
D.
Result of Schedule C Adjustments Above
Consistent
with the findings above, we have recalculated petitioner's
Schedule C loss from PK Production. Petitioner is entitled to a
loss of $1,748.19 on Schedule C for the year at issue.
Petitioner's adjusted gross income is also recomputed to reflect
this amount. Petitioner's recomputed adjusted gross income is
$28,919.35 for the year at issue.
2.
CASUALTY LOSS DEDUCTION
Section
165(a) allows a taxpayer to deduct any loss sustained during the
taxable year and not compensated for by insurance or otherwise. As
relevant here, section 165(c)(3) allows a deduction to an
individual for loss of "property not connected with a trade
or business or a transaction entered into for profit, if such loss
arises from fire, storm, shipwreck, or other casualty".
Pursuant
to section 165(h), personal casualty losses described under
section 165(c)(3) are deductible only to the extent that the loss
exceeds $100 and 10 percent of the taxpayer's adjusted gross
income. Moreover, such losses are deductible as itemized
deductions on Schedule A of the taxpayer's return.
Pursuant
to section 1.165-7(b)(1), Income Tax Regs., in the case of
property partially destroyed by casualty, the loss deductible for
purposes of section 165(a) is the difference between the fair
market value of the property immediately before the casualty and
the fair market value of the property immediately after the
casualty, with the deductible amount not to exceed the adjusted
basis of the property (fair market value approach).
To
establish the amount of the loss, the relevant fair market values
of the property "shall generally be ascertained by competent
appraisal." Sec. 1.165-7(a)(2)(i), Income Tax Regs. The
appraisal must be conducted in a manner to ensure that any
casualty loss deduction "be limited to the actual loss
resulting from damage to the property."
Id.
Section
1.165-7(a)(2)(ii), Income Tax Regs., provides that the cost of
repairs to the damaged property is acceptable as evidence of the
loss of value to the property (cost of repairs approach). In order
to use this alternative approach, the taxpayer must show: (1) The
repairs are necessary to restore the property to its condition
immediately before the casualty; (2) the amount spent for such
repairs is not excessive; (3) the repairs do not care for more
than the damage suffered; and (4) the value of the property after
the repairs does not as a result of the repairs exceed its value
immediately before the casualty.
Id.
For
the year at issue, petitioner claimed a casualty loss deduction of
$5,151.19 on Schedule A. Petitioner determined the casualty loss
amount on Form 4684, Casualties and Thefts, applying the fair
market value approach. On Form 4684, petitioner reported the fair
market value of the property before and after the casualty to be
$60,000 and $52,870, respectively. The $7,130 difference in the
fair market values reported was first reduced by $100, then
further reduced by $1,888.81, 10 percent of the adjusted gross
income shown on the return. Thereby, petitioner computed a
casualty loss of $5,151.19. No insurance reimbursement was
reported on the Form 4684.
A.
Fair Market Value Approach
At
trial, petitioner offered no evidence to substantiate the fair
market values reported on Form 4684. Petitioner did present a
Uniform Residential Appraisal Report (report), which estimated the
market value of petitioner's residence, as of
October
10, 1998
,
to be $53,000. The report makes no mention of the damage claimed
by petitioner, nor states that the appraised amount was based on a
value before or after the date of the storm. Because the appraised
value was determined as of
October
10, 1998
,
approximately 1 month after the storm and before any repairs were
made, we believe the $53,000 figure represents the fair market
value of the property taking into consideration any damage
resulting from the storm.<<ENDNOTE 6>> Since no
evidence of the fair market value of the property immediately
prior to the storm was presented at trial, petitioner has failed
to provide the information necessary to apply the fair market
value approach. Thus, petitioner is not entitled to the $5,151.19
casualty loss deduction claimed applying the fair market value
approach.
B.
Cost of Repairs Approach
At trial, petitioner presented many documents in
his attempt to substantiate the casualty loss deduction applying
the cost of repairs approach. The documents were stipulated by the
parties and are part of the record. Petitioner presented a copy
of: (1) The insurance settlement claim from State Farm in the
amount of $857.12; (2) a contract with Carl B. Adams to install a
new roof and replace rotten decking for $1,500; (3) three receipts
from Carl B. Adams acknowledging payment of $1,500; (4) a receipt
to haul and dump roofing materials for $125; (5) two receipts from
Commercial Sand totaling $50; (6) three receipts from Builders
Square Store # 1409 totaling $123.64; (7) a receipt from Olshan
Lumber Company for $1,070.11; and (8) a credit invoice from Olshan
Lumber Company for items returned in the amount of $280.74.
Accordingly, petitioner presented documentation totaling $2,588.01
to replace his roof and received $857.12 in insurance proceeds.
Thus, petitioner's net out-of-pocket expense was $1,730.88 (net
expense).
Petitioner
testified that he spent "over $4,000" to repair the
damage to his residence, but could not remember the exact amount.
While we are permitted to estimate the amount of a deduction under
certain circumstances, there must be evidence in the record upon
which to base our decision. Cohan v. Commissioner, 39 F.2d 540 (2d
Cir. 1930). Petitioner did not corroborate his testimony with any
evidence whatsoever to establish the $4,000 figure. It is well
settled that we are not required to accept a taxpayer's
self-serving testimony in the absence of corroborating evidence.
Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992).
Petitioner
presented receipts totaling only $2,588.01 for labor and materials
to replace the roof and received $857.12 in insurance proceeds.
Therefore, only the $1,730.88 of net expense corroborated by
documentary evidence is considered in determining petitioner's
casualty loss deduction.
We
need not determine on the merits if petitioner has met the four
substantiation requirements of section 1.165-7(a)(2)(ii), Income
Tax Regs., because petitioner's net expense is less than the
amount of the section 165(h) limitations. Applying the section
165(h) limitations, petitioner's net expense of $1,730.88 minus
the $100 limitation, or $1,630.88, is far less than 10 percent of
petitioner's recomputed adjusted gross income for the year at
issue.<<ENDNOTE 7>>
Petitioner
has failed to meet the minimum dollar amount threshold required to
deduct a casualty loss.<<ENDNOTE 8>>Since petitioner's
net expense does not exceed the limitations under section 165(h),
petitioner is precluded from deducting any of the net expense
incurred. Accordingly, petitioner is not entitled to a casualty
loss deduction applying the cost of repairs approach.
To
reflect the foregoing,
Decision
will be entered
under
Rule 155.
<<ENDNOTES>>
1/
In a Stipulation of Settled Issues filed with the Court on
Oct.
22, 2001
,
respondent conceded for the 1998 taxable year that petitioner is
entitled to: (1) A dependency exemption claimed for his son; (2)
head of household filing status; (3) an educational credit of
$1,250; and (4) business expense deductions on Schedule C, Profit
or Loss From Business, of $751 for legal or professional expense
and $121 for professional and musician dues.
At
trial, respondent conceded that petitioner is entitled to a
Schedule C expense deduction of $1,047.49 for music educator and
professional convention expenses incurred with respect to
petitioner's attending the International Association of Jazz
Educators Convention in
New
York City
.
2/
Sec. 7491 does not apply in this case to place the burden of proof
on respondent because petitioner neither alleged that sec. 7491
was applicable nor established that he fully complied with the
substantiation requirements of sec. 7491(a)(2)(A).
3/
Petitioner reported 12,370 business-related miles and claimed a
deduction of $4,182. The 1998 standard mileage rate of 32.5 cents
per mile multiplied by 12,370 miles equals $4,020.25.
4/
The partial mileage log was not introduced at trial.
5/
Assuming, arguendo, that petitioner was entitled to claim
unreimbursed employee expenses of $268.89 on Schedule A,
petitioner would not be entitled to a deduction because the total
unreimbursed employee expenses are not greater than 2 percent of
the recomputed adjusted gross income, as required under sec.
67(a).
6/
The Uniform Residential Appraisal Report states that
Oct.
10, 1998
,
was the date of inspection of the property.
7/
We recomputed petitioner's adjusted gross income to be $28,919.35,
10 percent of which is $2,892. See supra p. 16.
8/
Assuming, arguendo, that petitioner had corroborated $4,000 of
expense, the casualty loss deduction after the sec. 165(h)
limitations would be reduced to such a small amount that, when
added to the other items claimed on Schedule A, petitioner's total
itemized deductions would be less than the standard deduction for
the year at issue.
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