Les B. Martin and Millie A. Martin - Page 4

          furnishings and belongings were placed in storage.  Woodhead paid           
          approximately $1,700 of the expenses of shipping; Mr. Martin paid           
          the expenses incurred in moving from the company apartment to the           
          second apartment.  The record does not reveal the year in which             
          Woodhead paid the $1,700, but apparently the $1,700 was reported on         
          Mr. Martin's Form W-2 in the year paid.                                     
               Petitioners purchased a house in Kalamazoo that required               
          refurbishing.  Refurbishing was completed in 1989; thereafter,              
          petitioners moved into the refurbished house.                               
               On Schedule A of their 1989 return, petitioners claimed $3,272         
          in moving expenses.  The moving expenses were for costs incurred in         
          1989 in moving petitioners' furniture and belongings from storage           
          and their apartment to petitioners' newly refurbished house.                
          Respondent disallowed this deduction claiming (1) the expenses              
          incurred were not reasonably proximate in time to the commencement          
          of Mr. Martin's employment with Woodhead, and (2) the storage               
          expenses were not in-transit storage expenses.                              
          Unreimbursed Employee Business Expenses                                     
               On Schedule A of their 1989 return, petitioners claimed                
          $19,562 in unreimbursed employee business expenses.  Of this                
          amount, $5,020 was for membership fees and expenses in Gull Lake            
          Country Club (the country club) paid for by Woodhead and reported           
          on Mr. Martin's 1989 Form W-2.1  Mr. Martin joined the country club         

               1    Because Woodhead paid the country club fees and                   

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