Corey L. Wheir - Page 3

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               Respondent determined deficiencies of $2,168, $1,958, and              
          $1,470, respectively, in petitioner's Federal income taxes for              
          1999, 2000, and 2001.                                                       
               The issues for decision are:  (1) Whether, for the 3 years             
          in question, petitioner is entitled under section 162(a) and                
          (a)(2) to deductions for unreimbursed travel and transportation             
          expenses in connection with his employment and (2) whether, for             
          the 3 years, petitioner is entitled under section 162(a) to                 
          deductions for certain expenses incurred in a body building trade           
          or business activity.2                                                      
               Some of the facts were stipulated, and those facts, with the           
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioner's                
          legal residence was Wisconsin Rapids, Wisconsin.                            
               Petitioner is a boilermaker and has been engaged in this               
          activity since 1993.  During the years in issue, he worked                  
          exclusively within the State of Wisconsin at various plants and             
          paper mills throughout the State.  He was a member of the                   
          boilermakers' union, and all of his job assignments came from the           
          union.  The union was affiliated with the AFL-CIO.  Petitioner's            


               2    One additional adjustment in the notice of deficiency             
          is unreported interest income of $39 for the year 2000.  The                
          parties did not address this adjustment at trial; consequently,             
          the Court considers this item conceded by petitioner.  With                 
          respect to the two contested issues, the Court decides this case            
          without regard to the burden of proof under sec. 7491(a).                   




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