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Following concessions by the parties, the issues for decision
are: (1) Whether petitioners properly deducted as job expenses and
other miscellaneous deductions on Schedule A (itemized deductions)
of their 1989 tax return: $3,272 in moving expenses, $5,020 for
country club dues and expenses, $14,542 in unreimbursed employee
business expenses, $2,101 in investment expenses, $15,355 in job-
search expenses, and $3,612 for tax-work (audit) expenses; (2)
whether petitioners properly deducted $11,540 as Schedule C
business expenses for 1989; (3) whether petitioners properly
deducted miscellaneous expenses totaling $7,174 on Schedule A of
their 1990 tax return; (4) whether petitioners properly deducted
$12,489 as business expenses on Schedule C of their 1990 tax
return; and (5) whether petitioners are liable for the accuracy-
related penalty under section 6662(a) for 1989 and 1990.
All section references are to the Internal Revenue Code for
the years under consideration. All Rule references are to the Tax
Court Rules of Practice and Procedure. All dollar amounts have
been rounded.
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.
Petitioners, husband and wife, resided in Charlottesville,
Virginia, at the time they filed their petition. They timely filed
joint returns for 1989 and 1990. They submitted amended 1989 and
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