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Cottages rental. The only corroborating evidence in the record
showing that petitioners did travel to England is a “Copy
Statement” from Bruern Cottages reflecting a rental cost of
�4,556 (United Kingdom currency, pounds), which petitioner
requested in anticipation of litigation. Petitioner also
testified that he asked for reimbursement for these expenses from
his employer, the Chicago Department of Education. As of the
time of trial, the Chicago Department of Education had refused to
reimburse petitioner for said expenses.
We have taken into consideration petitioner’s testimony and
the “Copy Statement”, and we conclude that petitioners have
failed to satisfy the requirements of sections 162 and 274 as to
all job expenditures claimed as miscellaneous deductions in the
amount of $33,785. We find we cannot estimate any amounts of
petitioners’ deductions under the Cohan rule, and we sustain
respondent’s disallowance of petitioners’ claimed miscellaneous
deductions. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
Even had petitioners substantiated their claimed
miscellaneous deductions of $33,785 for expenses incurred during
taxable year 1999, they still would not be permitted the
deductions unless they demonstrated that the educational courses
taken maintained or improved the skills required in petitioner’s
employment as a high school English teacher.
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