Frank de Bane and Kathleen Naber-de Bane - Page 3

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               Respondent determined a deficiency in petitioners’ Federal             
          income tax of $5,277 for the taxable year 1996.  The sole issue             
          for decision is whether petitioners are entitled to numerous                
          business expense deductions disallowed by respondent.1                      
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Ukiah, California, on the date the petition was filed in this               
               During taxable year 1996, petitioners had combined wage and            
          salary income of $67,571.  Petitioner husband (petitioner) was              
          employed full time as a professor of physics and astronomy at               
          Mendocino College and part time as a professor of astronomy at              
          Santa Rosa Junior College.  Petitioner wife was employed full               
          time as a crisis counselor at Jefferson Elementary School in                
          Cloverdale, California.                                                     
               Petitioners filed a joint Federal income tax return for                
          taxable year 1996.  They filed with the return a Schedule C,                
          Profit or Loss From Business.  The schedule listed petitioner as            

          1Respondent’s adjustments to petitioners’ itemized                          
          deductions, self-mployment income tax, and self-employment income           
          tax deduction are computational and will be resolved by our                 
          holding on the issue in this case.  We note that respondent                 
          previously corrected two mathematical or clerical errors with               
          respect to petitioners’ itemized deductions.  The increase in the           
          tax shown on the return resulting from this correction has been             
          assessed and paid and is not at issue in this case.                         

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