Derk O. and Julia K. Pehrson - Page 2

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          Respondent determined a deficiency of $9,931 and an addition                
          to tax, under section 6651(a)(1), of $262 in petitioners' Federal           
          income tax for 1993.                                                        
          Following concessions by the parties, the issues remaining                  
          for decision are:  (1) Whether petitioners are entitled to an               
          automobile rental expense deduction for 1993 as a trade or                  
          business expense under section 162(a), and (2) whether                      
          petitioners are liable for the addition to tax, under section               
          6651(a)(1), for failure to timely file a Federal income tax                 
          return.                                                                     
          Some of the facts were stipulated, and those facts, with the                
          annexed exhibits are so found and are incorporated herein by                
          reference.  At the time the petition was filed, petitioners'                
          legal residence was Salt Lake City, Utah.                                   
               Derk O. Pehrson (petitioner husband) is a licensed real                
          estate broker in the State of Utah and was engaged in the                   
          business of real estate sales during the year at issue.                     
          Petitioner husband was also employed by Colonial Mortgage during            
          1993.  His wife, Julia K. Pehrson (petitioner wife), was employed           
          as a vice president of Hercules Credit Union (Hercules) during              
          the year at issue.                                                          
               In August 1993, petitioners rented a vehicle and drove,                
          along with their two young children, from Salt Lake City to                 
          Orlando, Florida.  On their way to Orlando, the family drove                





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