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how the air fare was paid and did not check with petitioner's
"employer" or discuss with petitioner the expenses he was
entitled to deduct. She stated in her testimony at trial that
she had no conversation with petitioner when she was preparing
his return with respect to whether he was entitled to deduct
expenses for airline tickets. She stated that she did not have
such a discussion, because--
these wrestlers were not getting reimbursed all those
years. They were not getting reimbursed according to
what I know. They were not getting reimbursed. * * *
these wrestlers always paid their own expenses * * * it
never occurred to me to ask him that [whether the cost
of the airline tickets had been included on the Forms
1099 furnished him by MBWC]. * * * if a salesman came
to me * * * I would ask him. They are different than
wrestlers are, but I would ask a wrestler too, but they
never did get reimbursed.
When this testimony of petitioner's return preparer is considered
in the light of the rest of the evidence in this record, it is
reasonable to infer that petitioner considered that his return
preparer had approved the way in which he was handling his
deductions for air fare on his return.
The record shows that in an economic sense a portion of the
airline fares was paid by the wrestlers. The amount a wrestler
got from a show was computed by taking a certain percent (usually
30 to 35 percent) of the gross amount received by the club for
putting the show on, after deductions of television costs, taxes,
and the transportation of wrestlers, where that was paid, and
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