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income tax for 1994 in the amount of $2,280 and an accuracy-
related penalty of $456 under section 6662(a).
The issues for decision are: (1) Whether petitioners are
entitled to deduct unreimbursed employee expenses under section
162 in the net amount of $15,123 for the 1994 tax year; (2)
whether petitioners overpaid their 1994 Federal income taxes; and
(3) whether petitioners are liable for an accuracy-related
penalty under section 6662(a) for the 1994 tax year.
Petitioners in their trial memorandum have also requested an
award of litigation costs. Such a request is premature. Rules
230-233.
The exhibits received into evidence are incorporated herein
by this reference. At the time the petition was filed,
petitioners resided in Austin, Texas. References to petitioner
are to Travis Sanderson. References to petitioner wife are to
Jayne Sanderson.
Background
Petitioner has an engineering degree from the University of
Texas at Arlington. At the time the petition was filed,
petitioner was working as an engineer for Dell Computers in
Austin, Texas. Petitioner wife is a certified public accountant
and has previously worked for the Internal Revenue Service as a
revenue agent in the Dallas/Fort Worth area.
In 1994, petitioner quit his job as a manufacturing test
engineer at Nokia Mobil Phones (Nokia) in Fort Worth, Texas. At
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