Robert M. Johnson and Janna D. Begole, f.k.a. Janna D. Johnson - Page 6




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                           1992                                                       
          Respondent     Respondent                                                   
          Claimed    Disallowed      Allowed                                          
          Credit Card Charges       $ 8,177      $ 6,711        $ 1,466               
          Client Costs                1,069          489            580               
          Expense Reimbursement      10,319        1,170          9,149               
          Miscellaneous               1,845          966            879               
          Meals/Entertainment         5,610        2,906          2,704               
          Total                   $27,020      $12,242        $14,778                 

                           1993                                                       
          Respondent     Respondent                                                   
          Claimed    Disallowed      Allowed                                          
          Credit Card Charges       $ 9,705      $ 6,781        $ 2,924               
          Client Costs               22,925       17,797          5,128               
          Expense Reimbursement      10,927        2,365          8,562               
          Professional Dues         20,124        8,001         12,123                
          Meals/Entertainment         1,655          331          1,324               
          Total                   $65,336      $35,275        $30,061                 

               On their individual joint Federal income tax returns for               
          1992 and 1993, petitioners claimed $20,792 and $25,594,                     
          respectively, as Schedule A itemized deductions for vehicle                 
          expenses, parking fees, travel expenses, and meals and                      
          entertainment expenses (hereinafter collectively referred to as             
          job expenses) incurred by petitioners in their capacities as                
          employees of DUI.                                                           
               On audit, relying largely on petitioner’s travel log,                  
          respondent allowed for each year $2,054 for vehicle expenses and            
          $223 for parking fees after determining that petitioner in 1992             
          and in 1993, in his capacity as an employee of DUI, made 21 trips           
          in his personal vehicle at an average of 300 miles per trip.                








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