3
various names on his calendar. Petitioners attached an exhibit,
a summary of petitioner's business travel for 1991, including
mileage totals, to their posttrial brief. This exhibit was not
offered or entered into evidence at trial, and therefore is not
evidence. See Rule 143(b).
Petitioner testified that it was the policy of the
accounting firm to reimburse employees for their mileage expense.
Petitioner testified that although he was entitled to
reimbursement from the accounting firm for his mileage expense,
he chose not to request reimbursement because of the financial
condition of the firm. Petitioner received no wages or
compensation from the accounting firm, although all other
employees were paid.
During 1991, petitioner traveled to Santa Fe, New Mexico, to
attend a required Government course in order to qualify to
perform certain audits. Petitioner drove from Dallas and stayed
in a hotel while in Santa Fe.
On their 1991 Federal income tax return, petitioners claimed
a Schedule A deduction for unreimbursed employee business
expenses of $8,188. These expenses included $5,913 for vehicle
expense, $150 for parking fees, tolls, and local transportation,
$1,775 for other business expenses, and $350 for union and
professional dues. Petitioner had been audited for a prior
year's return, which resulted in the allowance of a business
deduction for automobile expense based on 82 percent of his total
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