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262, however, expressly provides that no deduction shall be
allowed for personal, living, or family expenses.
The parties stipulated various copies of petitioner's
receipts, organized into the following categories: (1) Parking;
(2) dry cleaning; (3) shopping; (4) postage; (5) parking and
taxis; (6) Staples and Kinko's; (7) meals; (8) Jiffy Lube; (9)
cellular telephone; (10) telephone; (11) Office Max; (12)
insurance; (13) vehicle registration; (14) Unocal (auto repair);
and (15) an airline ticket and receipt. It is not apparent how,
or if, the expenses relate to petitioner's employment.
Petitioner's receipts included expenditures for personal dry
cleaning, clothes, bicycle equipment, haircuts, and groceries.
She admitted that she did not keep any records as to her claimed
meals and travel expenses. Respondent's counsel elicited
testimony from petitioner which demonstrated that petitioner was
unable to identify a business purpose for any of the expenses she
claimed as deductions.
Petitioner testified that she put all her receipts in a box
and let her accountant sort them out. Petitioner's accountant
admitted at trial that he mistakenly included in petitioner's
deductions expenses that were not deductible and that he agreed
with some of respondent's adjustments.
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