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and 2001 as income. We disagree. The examiner testified and her
bank deposits worksheet shows that she did not count funds
transferred from one account to another as income to petitioner
for 1998, 2000, and 2001.
Petitioner contends that the examiner improperly treated
overdraft transfers as taxable receipts. We disagree. The
examiner testified and her bank deposits worksheet shows that she
recorded overdraft transfers first as receipts, and then as
transfers from receipts, and so she did not treat overdraft
transfers as taxable receipts.
Petitioner made no other arguments relating to respondent’s
determination of his and Mrs. Clark’s gross income. We sustain
respondent’s determination of petitioner’s gross income for 1998,
2000, and 2001.
B. Whether Petitioner Had More Deductions Than Respondent
Allowed for 1998, 2000, and 2001
Petitioner contends that he had more deductions than
respondent allowed for 1998, 2000, and 2001. Specifically,
petitioner contends that he had substantial amounts of moving
expenses in 1998, business expenses in 2000, and unreimbursed
employee expenses in 2001.
1. Moving Expenses
Generally, a taxpayer may deduct moving expenses paid or
incurred during a taxable year in connection with beginning
qualifying work at a new qualifying location. Sec. 217(a). A
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