Edward M. Fontanilla - Page 2




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          issue, and all Rule references are to the Tax Court Rules of                 
          Practice and Procedure.  All dollar amounts are rounded to the               
          nearest dollar, unless otherwise indicated.                                  
               After concessions,1 the issues for decision are:  (1)                   
          Whether petitioner may deduct uniform expenses as unreimbursed               
          employee expenses.  We hold he may to the extent set out below.              
          (2) Whether petitioner is entitled to a deduction for charitable             
          contributions.  We hold he is to the extent set out below.  (3)              
          Whether petitioner may deduct travel expenses as unreimbursed                
          employee expenses.  We hold he may not.  (4) Whether petitioner              
          may deduct expenses he claimed that he incurred in a retail sales            
          activity.  We hold he may to the extent set out below.  (5)                  
          Whether petitioner is liable for an accuracy-related penalty for             
          the underpayment of income tax attributable to negligence or                 
          disregard of rules or regulations.  We hold he is.                           





               1Petitioner concedes that, having deducted $1,910 for real              
          estate taxes paid, it was improper to also deduct the same amount            
          as home mortgage interest, and that he received $17 of unreported            
          interest income.  Respondent concedes that petitioner paid                   
          $13,470 of home mortgage interest, $1,910 of real estate taxes,              
          $3,460 of State and local income taxes, and $283 for vehicle                 
          registration.  In addition, respondent concedes that petitioner              
          paid $338 and $112 of dues to the California Nurses Association              
          and Union Local 250, respectively.  Finally, petitioner claimed              
          $1,200 as a deduction for personal property taxes for which he               
          had no substantiation or recollection of the circumstances of                
          payment.  We consider this amount conceded by petitioner.                    




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