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The issues for decision are as follows:
(1) Whether petitioners are entitled to deduct unreimbursed
employee business expenses in the amount of $34,120 as claimed on
their 1993 Federal income tax return;
(2) whether petitioners are entitled to deduct additional
charitable contributions in excess of the amount allowed by
respondent for 1993; and
(3) whether petitioners are liable for the accuracy-related
penalty authorized by section 6662(a) with respect to the
aforementioned deductions.
We hold that petitioners are not entitled to the deductions
claimed in excess of the amount allowed by respondent and that
petitioners are liable for the accuracy-related penalty under
section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts with attached exhibits is incorporated
herein by this reference.
Thomas M. Gomez (petitioner) and Dolores F. Gomez resided in
La Habra, California, during 1993 and at the time they filed
their petition in this case.
Unreimbursed Employee Business Expense Deduction
During the first quarter of 1993, petitioner was employed as
a salesman for Information Handling Services (IHS) of Englewood,
Colorado. IHS had a company policy of paying its sales personnel
a $600 monthly allowance for automobile expenses. In accordance
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