Barry D. and Suzanne B. Whalley - Page 13

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          the San Mateo and San Jose conferences.  Accordingly, we allow              
          petitioners to deduct this amount.                                          
               For 1992, petitioners deducted $582 for a SWAT course                  
          allegedly attended by Mrs. Whalley.  To substantiate this                   
          expense, petitioners submitted a receipt signed by a "Kadie" for            
          that amount.  Petitioner, however, submitted the same receipt to            
          substantiate the cost of chairs he purportedly purchased from               
          Classic Oak for use in his home office.  Therefore, the receipt             
          is not reliable evidence of either expense.  Accordingly,                   
          petitioners have failed to meet their burden of proof with                  
          respect to this item.                                                       
               D. Parking Expenses                                                    
               In 1991 and 1992, Mrs. Whalley deducted $225 and $305,                 
          respectively, for alleged parking costs at California State                 
          University at Hayward.  Petitioner asserts that Mrs. Whalley was            
          "required to pay cash to park at the [school] meters."  Thus, she           
          did not have any parking receipts.  Rather, to substantiate these           
          expenses petitioners submitted daily parking permits.  However,             
          the language on the face of the parking permit directly conflicts           
          with petitioner's testimony, because it specifically indicates              
          that day permits are "not valid at parking meters."  Thus, the              
          evidence fails to establish that Mrs. Whalley paid for metered              
          parking at school.  Rather, it indicates that she was provided              
          with daily parking permits enabling her to park without charge.             






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