James Lawton Robertson and Lillian Janette Humber Robertson - Page 7

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          amount of reimbursement petitioner received from the State of               
          Mississippi on their Federal joint income tax returns for 1990,             
          1991, and 1992.  Furthermore, petitioners deducted travel, lodging,         
          and meal expenses that were not reimbursed by the State of                  
          Mississippi for petitioner's attendance at the court in Jackson.            
          Notice of Deficiency                                                        
               In the notice of deficiency, respondent determined that                
          petitioners underreported their income for each of the years in             
          issue by the amount of travel, lodging, and meal expense                    
          reimbursements petitioner received from the State of Mississippi.           
          Respondent further disallowed petitioners' deduction for                    
          unreimbursed travel, lodging, and meal expenses for the years in            
          issue.                                                                      
               At trial, respondent conceded that the transportation expenses         
          incurred by petitioner relating to his travel between jobs in               
          Jackson, Mississippi, as a Justice of the Mississippi Supreme Court         
          and Oxford, Mississippi, as an adjunct professor of law at the              
          University of Mississippi are deductible for those days in which            
          petitioner traveled from Jackson to Oxford for the purpose of               
          teaching classes.  See Rev. Rul. 61-67, 1961-1 C.B. 25, modified by         
          Rev. Rul. 76-453, 1976-2 C.B. 86.                                           
                                       OPINION                                        
               Our task herein is to decide whether the travel, lodging, and          
          meal expense reimbursements paid to petitioner for his attendance           





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