Regina B. Jackson - Page 2

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          job search expenses; and whether petitioner is liable for the               
          additions to tax determined by respondent.  Unless otherwise                
          indicated, all section references are to the Internal Revenue               
          Code in effect for the years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Gaithersburg, Maryland, at the time that              
          she filed her petition.                                                     
               During 1993 and 1994, petitioner was employed as a program             
          analyst by the Department of the Air Force.  In 1994, petitioner            
          received a master's degree in general administration.  During               
          1994, petitioner took educational courses related to her                    
          attainment of the master's degree.  She received wage income of             
          $48,147.38 in 1993 and $59,010.41 in 1994.  She received interest           
          income of $179 in 1993 and $554 in 1994 from various financial              
          institutions.  During 1993, petitioner received Maryland State              
          income tax refunds of $636 for 1990 and $1,156 for 1991, a total            
          of $1,792.                                                                  
               On the returns she prepared for 1993 and 1994, petitioner              
          claimed, among other things, the following items as deductions:             

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