Edward M. Fontanilla - Page 3




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                                   FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.                
          The stipulated facts and the accompanying exhibits are                       
          incorporated into our findings by this reference.  At the time               
          the petition in this case was filed, petitioner resided in Daly              
          City, California.                                                            
               Petitioner is a registered nurse and is required to wear a              
          nurse's white uniform while on duty at the hospitals.  For the               
          year at issue, petitioner claimed $2,850 as a miscellaneous                  
          deduction for work shoes, uniforms, and union dues.                          
               Petitioner worked at three hospitals in the San Francisco               
          Bay area for several months during the year at issue.  On days               
          that he worked at more than one hospital, petitioner would work              
          for a few hours at one hospital and then drive to another                    
          hospital where he would work for a few more hours.  Petitioner               
          claimed $3,750 as an unreimbursed employee expense for job                   
          travel.                                                                      
               Petitioner is a devout Catholic and regularly attends San               
          Pedro Holy Angel Church in Daly City.  Petitioner claimed a                  
          deduction of $260 for cash contributions to this church.                     
          Petitioner also claimed a $500 deduction for a contribution of               
          old clothes to the Salvation Army.                                           
               During the year at issue, petitioner engaged in a retail                
          sales activity of selling magnets that were supposed to promote              





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