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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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