Wickie B. Whalen - Page 3

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               Respondent determined for 2001 a deficiency in petitioner’s            
          Federal income tax of $7,171 and an accuracy-related penalty                
          under section 6662(a) of $1,434.20.                                         
               The issues for decision are whether petitioner is:  (1)                
          Entitled to deductions on Schedule A, Itemized Deductions,                  
          greater than those respondent allowed; and (2) liable for an                
          accuracy-related penalty under section 6662(a).                             
               The stipulated facts and the exhibits received into evidence           
          are incorporated herein by reference.  At the time the petition             
          in this case was filed, petitioner resided in Miami, Florida.               
                                     Background                                       
               Petitioner has been employed as a college professor with               
          Miami-Dade Community College (the college) since 1976.  He                  
          teaches in the Department of Visual Arts and philosophy.                    
               During 2001, petitioner taught art history I and II, general           
          education humanities, and art appreciation.  As part of a                   
          consortium, he also taught a summer program for the college in              
          Italy.  Those courses consisted of art history, art appreciation,           
          humanities, world history, and Italian art history.                         
          A.   Petitioner’s Tax Return for 2001                                       
               Petitioner timely filed with the Internal Revenue Service a            
          Form 1040, U.S. Individual Income Tax Return, for 2001.  Attached           
          to the return were various forms including a Schedule A and a               
          Form 2106, Employee Business Expenses.                                      






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