Bill R. and Carolina N. Thomas - Page 2

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          decision is whether petitioners are entitled to a Schedule A                
          deduction claimed for unreimbursed employee business expenses.              
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and exhibits received into evidence are            
          incorporated herein by this reference.  Petitioners resided in              
          Dallas, Texas, at the time their petition was filed.                        
               During the tax year in question, Bill R. Thomas (petitioner)           
          was a practicing certified public accountant and owner of an                
          accounting practice, Thomas & Associates, P.C.  Petitioner                  
          managed the office, supervised field audits, and performed                  
          consulting work.  The business was organized as a professional              
          corporation for which corporate tax returns were filed.                     
               Petitioner owned a second business, Thomas Business                    
          Brokerage, a sole proprietorship engaged in the sale of                     
          companies.  Both the accounting practice and brokerage business             
          required petitioner to travel locally and away from home.                   
          Petitioners owned four cars.  Petitioner used one car for                   
          business travel, commuting, and some personal travel.  Petitioner           
          recorded the odometer readings of this car at the beginning and             
          end of the taxable year.  Petitioner also maintained a daily                
          calendar on which he recorded names representing the clients with           
          whom he met on that day.  He did not write down the nature of the           
          business conducted or a location of the meeting.                            
               At trial, petitioner testified as to approximate distances             
          traveled and the nature of the business involved with respect to            




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