Theldon and Mary Parrett - Page 6

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          unreimbursed employee business expenses, the Court notes that               
          commuting expenses incurred by a taxpayer to and from the                   
          taxpayer's place of employment are personal expenses and are not            
          deductible.  Sec. 262; Commissioner v. Flowers, 326 U.S. 465                
          (1946).  Petitioners presented no argument and cited no authority           
          to the contrary.  Petitioners contended at trial that they had              
          incurred expenses for tax preparation and for special clothing              
          required by Mrs. Parrett in her employment.  The Court holds                
          that, to the extent any expenses of this nature were incurred,              
          the amounts would not exceed 2 percent of petitioners' adjusted             
          gross income each year, and, therefore, under section 67(a),                
          petitioners are not entitled to deductions for those items.                 
               With respect to charitable contributions, petitioners                  
          produced no documentary evidence to substantiate their                      
          contributions for the 2 years at issue.  Petitioners testified              
          that their records were destroyed in the flooding of their home.            
          Even though their records were destroyed, petitioners made no               
          attempt to reconstruct evidence of their contributions for the 2            
          years in question.  However, it appears to the Court that                   
          petitioners did make qualifying charitable contributions during             
          the years at issue and, therefore, under the Court's                        
          discretionary authority pursuant to Cohan v. Commissioner, 39               
          F.2d 540, 543-544 (2d Cir. 1930), allows petitioners charitable             
          contribution deductions of $300 for each year at issue.                     

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