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and computers. Petitioner’s travel and meal deductions are for
the cost of overnight meals and lodging while he performed work
for the Navy. In addition, petitioner reported wage income of
$54,5073 and nontaxable pension income of $4,627. Petitioner
claimed a $3,700 standard deduction.
Petitioner filed his 1993 Federal tax return on June 13,
1994. Petitioner testified that he did not file his return on
time because he was busy working extra hours for the INS during
an immigration crisis. Petitioner did not file a Form 4868 with
the Internal Revenue Service, requesting an automatic extension
to file his return.
In the notice of deficiency, respondent disallowed all of
the expenses. Respondent has conceded that petitioner has
verified expenditures for office, travel, and meal expenses.
Respondent, however, asserts that deductions relating to
“Professional books and equipment” and the business use of the
automobile have not been substantiated. Respondent also
determined that petitioner is liable for the section 6651(a)
addition to tax.
3 Petitioner received the following Form W-2 wage income:
Entity Amount
Department of Justice (INS) $42,588.92
Defense Finance and Accounting Service 7,126.44
Chapman University 3,000.00
Persupp Det Camp Pendleton 1,792.52
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