Broady
...s. The unreimbursed expense of $1,709 comprised a vehicle expense of $559 and vehicle depreciation of $1,150, the latter of which duplicates the depreciation and sec. 179 expense deduction claimed on her Schedule C. -Both of theses were incurred as part of petitioner DeClerk’s employment with IONA Senior Services during the 1999 taxable year. -During 1999 taxable year, petitioner Clifford L. Brody was the chairman of the board, chief executive officer, and shareholder of Kids Own America, Inc. (KOA). As of April 1999, he owned 134,625 shares of common stock, or 53.37 percent of KOA -Also during the 1999 taxable year, petitioner Barbara J. DeClerk was the treasurer, secretary, and director of KOA. In addition to her positions at KOA, petitioner DeClerk was also a fundraiser for IONA Senior Services. -Practitioners attached a Schedule A, Itemized Deductions, to report the following unreimbursed employee expenses to the amount of 60,201.10. They also attached two Schedules C, Profit or Loss From Business, to their 1999 tax return. One Schedule C pertained to petitioner DeClerk’s “Principal Business or Profession” of “ Fund Raising” and reported a depreciation and section 179 expense deduction of 1,150. -The other Schedule C claimed money for the amount of 43,294. -Respondent determined that petitioners were not entitled to itemized deductions for unrei...