- 13 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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