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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency of $3,004 in petitioner's
Federal income tax for the year 1996.
We must decide: (1) Whether respondent erroneously
disallowed some items from petitioner’s Schedule C, Profit or
Loss From Business; and (2) whether petitioner is entitled to
deductions in excess of those allowed by respondent.
Some of the facts have been stipulated and are so found.
Petitioner resided in Van Nuys, California, at the time he filed
his petition.
Petitioner is a computer instructor/systems analyst for
three employers. The employers are California State University,
Pacific Travel and Trade Schools, and Computer Learning Centers,
Inc. Petitioner received Forms W-2 for 1996 from the three
employers.
On his 1996 Federal income tax return, petitioner deducted
$6,850 for medical expenses, prior to the floor of 7.5 percent of
adjusted gross income under section 213(a), $2,175 as a capital
loss, $1,500 for moving expenses, $9,512.50 for a Schedule C
business loss, and the rounded amount of $6,250 as job and other
expenses, before the 2-percent adjusted gross income limitation
under section 67. Respondent disallowed for lack of
substantiation $6,770 of the medical expenses, $2,175 of capital
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