Les B. Martin and Millie A. Martin - Page 2

               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           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011