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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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