Lawrence Moore - Page 2

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                                  FINDINGS OF FACT                                    
               Petitioner resided in Toledo, Ohio, at the time the petition           
          in this case was filed.                                                     
               Petitioner timely filed his 1999 Federal income tax return.            
          Attached to the return was a Form W-2, Wage and Tax Statement,              
          from "Four-A Electric, Inc." reporting wages to petitioner of               
          $54,819.  Petitioner reported the amount of his wages on line 7             
          of the return.  On Schedule A, Itemized Deductions, of his                  
          return, petitioner claimed deductions for State and local taxes             
          of $4,999, and charitable contributions of $100.  He also claimed           
          on Schedule A miscellaneous itemized deductions for unreimbursed            
          employee expenses of $39,224, after reduction for the 2-percent             
          floor of section 67.1                                                       
               From adjusted gross income of $55,207, petitioner deducted             
          total itemized deductions of $44,323, and a personal exemption of           
          $2,750, to arrive at taxable income of $8,134 on which he                   
          computed a tax due of $1,219.  As petitioner had total                      
          withholding credits of $6,197, he claimed an overpayment of                 
          $4,978.  Petitioner did not attach Form 6251, Alternative Minimum           
          Tax-Individuals, to his 1999 income tax return, or report any               
          liability for the alternative minimum tax on line 51 of Form                
          1040, U.S. Individual Income Tax Return.                                    

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year in issue.                  

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