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Respondent determined a deficiency in petitioner’s Federal
income tax of $1,635 for 2002. The issue for decision is whether
petitioner is entitled to claim itemized deductions in excess of
those allowed by respondent.
The exhibits received in evidence are incorporated herein by
reference. At the time the petition was filed, petitioner
resided in Simi Valley, California.
Background
The parties could not reach agreement on a stipulation of
facts. There are, however, some documents upon which the parties
were in mutual agreement. The record, nevertheless, remains
sparse.
As best as the Court can discern, petitioner was employed as
“Property Manager” for National Stores, Inc. in Gardena,
California, apparently doing business as “Clothestime” (Stores).
Stores was by its own description “a regional leader in quality
off-price retail apparel.” Petitioner’s duties as Stores’
property manager included responsibility for: (a) Locating new
real estate opportunities; (b) reviewing active leases; (c)
sustaining relationships with tenants, including collecting
rents; and (d) preserving relationships with vendors responsible
for maintaining the properties.
During 2002, Stores, facing the threat of bankruptcy,
instituted a policy under which it would not reimburse
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