Edward and Ruth Kelly - Page 11

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            Kelly might not have been bringing in enough business to warrant                          
            being reimbursed for additional expenses.                                                 
                  Any explanation why some of the expenses were not reimbursed                        
            would be pure speculation, as petitioner's counsel chose not to                           
            elicit any testimony from Mr. Kelly regarding his failure to                              
            request and obtain reimbursement of his entertainment expenses                            
            from his employer.                                                                        
                  Petitioner has offered no evidence to show that the                                 
            deductions in issue were grossly erroneous.  There has been no                            
            showing that the deductions were "phony" or otherwise grossly                             
            erroneous for purposes of the innocent spouse requirement.                                
            Purcell v. Commissioner, supra.                                                           
                              For the foregoing reasons,                                              
                                                            An order will be issued                   
                                                      denying petitioner's Motion                     
                                                      for Reconsideration.                            



















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