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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
(continued...)
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