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v. Commissioner, supra at 543-544, we find that petitioners are
entitled to $500 in contributions for each of the 3 taxable
years.
Petitioners purchased supplies, teaching aides, and computer
items in connection with their teaching activity. In addition,
petitioners had expenditures for the maintenance of their
computers. To some extent, the computers were used for personal
purposes. At trial, petitioners provided some documentation of
their expenditures concerning their employee business expenses.
The amounts documented were less than one-half of the amounts
claimed for 1992 and 1993. However, some of the documentation
for one year provided a basis for allowance of a similar amount
in the other year. For example, petitioners provided
substantiation of $771.92 for union dues in 1993, and respondent
conceded that amount.
The claimed deductions relating to computers are subject to
the more rigorous requirements of section 274(d) because they are
"listed property" as described in section 274(d)(4) and listed in
section 280F(d)(4)(A)(iv). See also sec. 1.274-5T(a), Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). In that
regard, petitioners provided specific proof of computer
expenditures during 1992 and 1993 in the amounts of $1,224.40 and
$1,668.93. Taking into consideration personal use, we hold that
petitioners are entitled to employee computer-related business
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