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the M&IE rates is limited to the incidental expense portions of
those rates and that his deductions must be determined
accordingly. Unless otherwise indicated, section references are
to the Internal Revenue Code, and Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Most facts were stipulated. The parties’ stipulations of
fact and the exhibits submitted therewith are incorporated herein
by this reference. The stipulations of fact are found
accordingly. Petitioners resided in Freeland, Washington
(Freeland), when we filed their petition. Freeland is a
community on Whidbey Island, Washington, located in the Puget
Sound approximately 70 miles east of Port Angeles, Washington,
and approximately 75 miles north of Tacoma, Washington.1
Petitioners are husband and wife. They and their daughter
resided during the subject years in a house (personal residence)
that petitioners owned in Freeland. During 1994, petitioner paid
$12,640 of mortgage interest and $4,412 of real estate taxes on
the personal residence. He paid $11,002 of mortgage interest and
$4,799 of real estate taxes on the personal residence during
1996.
1 We have taken judicial notice of this fact.
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