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explained that, at the time of trial, she resided in Bermuda and
could not find her receipts. She also testified that she
contributed money to her church but did not provide any details
to support these contributions. Accordingly, respondent is
sustained on this issue.
b. Telephone Expenses
Petitioners claimed deductions for 1997, 1998, and 1999 for
unreimbursed employee expenses for a second telephone line in
their home. Respondent disallowed the claimed telephone line
expense deductions in full because petitioners did not
substantiate the claimed amounts. Also, respondent was not
satisfied that Mrs. Whitehurst worked out of a home office, that
she had a home office for the convenience of her employer, and
that she had a business purpose for the use of the computer.
Mrs. Whitehurst was employed full time during the years at
issue as an environmental specialist for Horne Engineering
Services Inc. (Horne), an engineering company. From 1995 to 1997
Horne had a contract with the U.S. Army, and Mrs. Whitehurst
worked at the Aberdeen Proving Ground in Edgewood, Maryland.
Mrs. Whitehurst operated the Army’s environmental hotline and
issued daily environmental regulatory summaries for Army staff.
In November 1997, around the time that Horne’s contract with
the Army ended, Mrs. Whitehurst worked at Horne’s offices in Bel
Air, Maryland. Because Horne did not have a desk or computer at
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