James Lawton Robertson and Lillian Janette Humber Robertson - Page 2

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                              Year      Deficiency                                    
                              1990      $6,400.27                                     
                              1991      5,841.34                                      
                              1992      3,922.00                                      
          The issue for decision is whether reimbursement by the State of             
          Mississippi for certain travel, lodging, and meal expenses incurred         
          by James Lawton Robertson (petitioner) during his term as a Justice         
          of the Mississippi Supreme Court is excludable from petitioners'            
          income.  To the extent petitioner incurred unreimbursed travel,             
          lodging, and meal expenses, we must also decide whether those               
          expenses are deductible from petitioners' income.                           
               Unless otherwise indicated, all section references are to the          
          Internal Revenue Code as in effect for the years in issue.  All             
          Rule references are to the Tax Court Rules of Practice and                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
               At the time the petition was filed, petitioner resided in              
          Jackson, Mississippi, and petitioner's wife, Lillian Janette Humber         
          Robertson (Mrs. Robertson), resided in Oxford, Mississippi.                 
          Petitioner's Appointment and Election as a Justice to the                   
          Mississippi Supreme Court                                                   
               In 1965, petitioner began practicing law in Greenville,                
          Mississippi.  In 1979, petitioner became a full-time law professor          

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