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deductions for miscellaneous expenses incurred in job seeking and
for tax return preparation in the amounts of $887 and $65,
respectively.
Trade or Business Expenses
During the years in issue, Paula was employed full time as a
dance and physical education teacher at Florin High School in
Sacramento, California. She taught beginning jazz classes and
gave instruction on technique and execution for the drill team.
Additionally, she developed "Masterpiece Dance Theater", a
touring company with dance performances by students. Petitioners
deducted tickets to dance concerts, clothing, shoes, and other
miscellaneous items related to Paula's employment at the school
as miscellaneous itemized deductions on their 1992, 1993, and
1994 Federal income tax returns.
Chartering Activity
In 1992, 1993, and 1994, petitioners owned two boats: A 30-
foot wooden Chris Craft river cruiser and a 24-foot cuddy cabin
(the boats). Petitioners have owned other boats for recreation
in the past. Petitioners publicized that the boats were
available for 12-hour chartered boating and fishing trips on the
Sacramento River and Lake Comanche, California. Petitioners
called their charter business "It Takes 2" and charged $240 to
charter a boat. Petitioners provided fishing gear, bait, and
safety vests for their customers.
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