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After concessions,1 we must decide: (1) Whether petitioner
may deduct any of his unreimbursed employee expenses in 1992; (2)
whether petitioner failed to timely file his Federal income tax
return for the 1992 tax year; and (3) whether petitioner is
liable for the accuracy-related penalty.
All section references are to the Internal Revenue Code in
effect for the year in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Petitioner resided in San Jose, California, at the time he
filed the petition. Petitioner filed his 1992 Federal income tax
return on February 14, 1995 (the return). On the return,
petitioner deducted $19,781 in unreimbursed employee expenses.2
1 At trial, the parties entered into an oral stipulation of
settled issues. In that stipulation, respondent concedes that
$746 of interest which respondent determined to be income to
petitioner was not taxable. Petitioner concedes the following:
(1) A $1,493.44 deduction for clothing expenses; (2) a telephone
expense deduction of $606.79; (3) a $150 educational expense
which petitioner's employer reimbursed him for; and (4) a $15.32
expense incurred at the Santa Anita Firing Range that was
inadvertently deducted twice.
2 The parties have stipulated that petitioner has
substantiated all of his unreimbursed employee expenses.
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