Rodney J. and Lorraina S. Huang - Page 2

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          references are to the Tax Court Rules of Practice and Procedure.            
          The issues for decision are whether petitioners are entitled to             
          deduct expenses claimed on Schedules A, C, and E of their                   
          Forms 1040 for the years in issue and whether they are liable for           
          the penalties determined by respondent.                                     
                                  FINDINGS OF FACT                                    
               Petitioners resided in Hawaii at the time that they filed              
          their petition.                                                             
               During 1992 and 1993, petitioners maintained journals of               
          their expenditures by cash and by check, including but not                  
          limited to expenditures for meals at restaurants, for groceries,            
          for items at department stores and at drugstores, for                       
          unidentified supplies, and for medical expenses.  The recorded              
          expenditures were transferred to a monthly summary.  On the                 
          monthly summary, the majority of the expenditures, including auto           
          expense, electricity, entertainment, laundry ($60 per month),               
          rent, supplies, telephone, and water, were claimed to be                    
          “deductible”.  The monthly allocations recorded for 1992 and 1993           
          were as follows:                                                            













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