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Respondent determined a deficiency in petitioners’ Federal
income tax of $2,242, and an addition to tax of $488.25 under
section 6651(a)(1), for the taxable year 1998.
The issues for decision are: (1) Whether petitioners are
entitled to certain miscellaneous itemized deductions in the
amount of $14,971.38 for “job seeking expenses”; and (2) whether
petitioners are liable for an addition to tax under section
6651(a)(1) for failing to file timely their Federal income tax
return.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits thereto are
incorporated herein by this reference. Petitioners resided in
San Francisco, California, on the date the petition was filed in
this case.
During 1998, Mark W. Franklin (petitioner) was employed as a
production specialist1 for United Airlines. His employment
location was the United Airlines facility at the San Francisco
International Airport.
Between January and the end of March 1998, Anita P. Franklin
(petitioner wife) was unemployed and had been unemployed for the
previous 4 years. At the end of March, she began working for the
County of Alameda in Oakland, California, in an administrative
1Petitioner also described his job as a “computer terminal
technician position”.
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