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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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