Richard A. Gerstenberger - Page 6




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          petitioner’s occupation as mechanic and Michael J. Brady of the             
          “MICHAEL J. BRADY ACCTY CORP” as the paid preparer of that                  
          return.                                                                     
               The 1995 return reported the following items and amounts of            
          income or loss on page 1 on the lines indicated:                            
                                               Line on Page 1                         
                  Item of Income or Loss       of 1995 Return    Amount               
               Wages, salaries, tips, etc.            7          $59,192              
                 Taxable interest income            8a           165                  
                Business income or (loss)            12         (40,439)              
                Unemployment compensation            19          2,501                
             Net operating loss (NOL) carry-         21         (20,550)              
                       over to 1995                                                   
          The 1995 return reported on page 1, on lines 22 and 31, respec-             
          tively, “total income” and “adjusted gross income” of $869.                 
               The 1995 return included Schedule A, Itemized Deductions               
          (Schedule A), lines 20 through 26 of which were entitled “Job               
          Expenses and Most Other Miscellaneous Deductions” (job-expense              
          section).  The 1995 return claimed on line 20 of Schedule A,                
          entitled “Unreimbursed employee expenses”, (1) $1,936 for “UNION            
          AND PROFESSIONAL DUES” and (2) $11,580 “FROM FORM 2106".  Form              
          2106, Employee Business Expenses (Form 2106), attached to the               
          1995 return listed the following claimed expenses on the lines              
          indicated:                                                                  












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