Charles and Beatrice M. Reynolds - Page 3




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          automobile and travel and meals and entertainment expense                   
          deductions; (7) whether petitioners are entitled to claim for               
          1994 an additional expense under section 179 for a depreciable              
          asset; and (8) whether there is underpayment of petitioners’ tax            
          due to negligence.                                                          
               Some of the facts have been stipulated.  Stipulated facts              
          and accompanying exhibits are incorporated herein by reference.             
                                  FINDINGS OF FACT                                    
               Petitioners resided in Lisle, Illinois, at the time the                
          petition was filed in this case.                                            
               During the years at issue and at the time of trial, Mrs.               
          Reynolds was a manager for Service America Corp., and petitioner            
          was a supervisory internal revenue agent.  Petitioner has been an           
          employee of the Internal Revenue Service (IRS) since 1976.                  
          Before his employment with the IRS, petitioner was an electronics           
          engineer with the Department of Defense.  Petitioner also holds a           
          certified public accountant’s license from the State of South               
          Carolina, is a 1982 graduate of the Indiana University Law                  
          School, and was licensed as an attorney by the State of Illinois            
          in 1985.                                                                    
               Petitioner prepared the joint individual Federal income tax            
          returns for himself and his wife for 1993 and 1994.                         
               In April of 1998, a year after respondent issued the                   
          statutory notice of deficiency in this case, respondent replied             





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