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Petitioners also argue that petitioner wife was not
reimbursed for certain expenses which she paid in connection with
her employment as a schoolteacher. Petitioner wife did not
testify at trial. Petitioners submitted some records of her
claimed vehicle and travel expenses for 1991 which are not
helpful because they do not indicate whether or not the listed
expenses were reimbursed. They submitted no records of her
expenses for 1990 or 1992. After reviewing the record, we find
that petitioner husband's testimony with respect to petitioner
wife's claimed expenses and the little written evidence in the
record does not satisfy the substantiation requirements of
section 274(d).
We hold that petitioner husband's unreimbursed expenses for
the use of his automobile in the course of his employment as an
auditor are deductible as miscellaneous itemized deductions to
the extent the total of such expenses and petitioners' other
allowed miscellaneous itemized deductions for the taxable years
in issue exceed the section 67(a) limitation for such years.
The fourth issue for decision is whether petitioners are
entitled to charitable contribution deductions in excess of the
amounts allowed by respondent. Petitioners claimed and
respondent disallowed in the statutory notice of deficiency
deductions for charitable contributions as follows:
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