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The issues for our consideration are: (1) Whether the
correspondence in this case from respondent's employee estopped
respondent from determining a deficiency in petitioners' 1995
Federal income tax; (2) whether respondent correctly determined
that petitioners must recognize income from Social Security
benefits in the amount of $7,643 for the taxable year 1995; (3)
whether petitioners are entitled to deduct $11,282 in alleged
job-hunting expenses; (4) whether petitioners are entitled to
deduct temporary living expenses of $5,240; (5) whether
petitioners' gambling losses are limited to their income from
gambling for taxable year 1995; and (6) whether petitioners are
liable for the accuracy-related penalty under section 6662(a).
Separate Findings of Fact and Opinion are hereafter set forth
with respect to each of the first five issues. Those portions of
the Stipulation of Facts that pertain to a particular issue are
incorporated by this reference in the Findings of Fact for the
issue to which they relate.
I. 1994 Refund Letter
FINDINGS OF FACT
At the time of the filing of the petition in this case,
petitioner John Allen Lyle resided in El Paso, Texas. Petitioner
Glenna A. Lyle resided in Nashville, Tennessee. Glenna A. Lyle
is a petitioner in this case because she joined in filing Federal
income tax returns with her husband John Allen Lyle (petitioner).
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