Gary Wilson - Page 6




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          $417.  Petitioner filed 1993 State income tax returns for                   
          California and Idaho.  In 1993 petitioner purchased a parcel of             
          vacant land in Valley County, Idaho.                                        
               On August 21, 1995, petitioner filed his 1992 Form 1040,               
          U.S. Individual Income Tax Return.  On this return, petitioner              
          showed his address as 3800 W. Devonshire, Hemet, California 92545           
          (the Hemet address).  Petitioner designated his filing status as            
          single and claimed only his personal exemption.  Petitioner                 
          attached to his return a Form 2106, Employee Business Expenses,             
          on which he claimed the following deductions for unreimbursed               
          employee business expenses:                                                 
                             Expense        Amount                                   
                    1.  Vehicle              $5,443.20                                
                    2.  Parking fee               867.00                              
                    3.  Travel                    8,211.00                            
                    4.  Business not on lines 1-3   5,290.00                          
                    5.  Meals                       1,492.80                          
          Total claimed deductions   21,304.00                                        
               On August 21, 1995, petitioner filed his 1993 Form 1040.               
          Petitioner again showed the Hemet address as his address.                   
          Petitioner designated his filing status as single and claimed               
          only his personal exemption.  Petitioner attached a Form 2106 to            
          his return and claimed the following deductions for unreimbursed            
          employee business expenses:                                                 











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