Thomas M. and Dolores F. Gomez - Page 4




                                        - 4 -                                          

               On their 1993 joint income tax return, petitioners claimed a            
          deduction of $35,667 for unreimbursed employee business                      
          expenses.2                                                                   
          Charitable Contribution Deduction                                            
               On their 1993 return, petitioners claimed a deduction for               
          charitable contributions as follows:                                         
               La Habra Christian Church           $9,286                              
               Pacific Christian College           4,800                               
               Angeles Christian College           4,800                               
               Calvary Chapel                      7,200                               
               Total deduction claimed        26,086                                   
               The amount of the charitable contribution deduction for 1993            
          was estimated by petitioner and given to the return preparer who             
          prepared petitioners' 1993 return.  Petitioners did not maintain             
          any documentation regarding the contributions claimed.3                      





               2The deduction was calculated as follows:                               
                    Form 2106 employee business expenses  $12,048                      
                    Meals and entertainment expense          8,500                     
                         Less 20% reduction             (1,700)                        
                    Other business expenses                                            
                         Fares                               7,346                     
                         Lodging                             7,573                     
                    Miscellaneous expenses                                             
                         Telephone bills                     1,900                     
                    Total unreimbursed                                                 
                    employee business expenses          35,667                         
               3Two of the charitable organizations listed on the return--             
          Pacific Christian College and La Habra Christian Church--had no              
          record of any charitable giving by petitioners during 1993.  The             
          record is silent with respect to the other organizations listed              
          on petitioners' 1993 return.                                                 

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