Michael G. and Kate M. Lavigne - Page 3




                                        - 2 -                                         

               Respondent determined deficiencies of $4,097 and $7,658 in             
          petitioners' Federal income taxes, respectively, for 1998 and               
          1999 and corresponding penalties under section 6662(a) in the               
          amounts of $819 and $1,532.                                                 
               Some of the facts were stipulated, and those facts, with the           
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioners'                
          legal residence was Albuquerque, New Mexico.                                
               For each of the years in question, petitioners claimed                 
          itemized deductions on a Schedule A, Itemized Deductions, of                
          their Federal income tax return.  For 1998, petitioners claimed             
          itemized deductions totaling $26,446, of which $15,484 was                  
          disallowed by respondent.  For 1999, petitioners deducted                   
          $38,113, of which $27,368 was disallowed by respondent.                     
          Petitioners, nevertheless, were allowed itemized deductions for             
          both years, since the total of their other claimed and allowed              
          deductions exceeded the standard deduction under section 63(c).             
          For the 2 years at issue, the disallowed deductions consisted of            
          charitable contributions, job expenses, and other miscellaneous             
          deductions.  Additionally, for 1999, respondent disallowed an               
          itemized deduction for gambling losses of $4,000.                           
               The issues for decision are: (1) Whether petitioners are               
          entitled to the disallowed itemized deductions for charitable               
          contributions, job expenses, and other miscellaneous deductions             





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