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petitioner’s sole evidence that he returned to the condo, are
either irrelevant or of little probative value. Some of the bank
statements were dated 2001 or had dates that were illegible. To
the extent that the statements were dated 2000, they fail to
cover the periods for which petitioner was unemployed during that
year.
Petitioner did not present a complete set of utility bills
for 2000. The utility bills that were presented were in either
Mr. or Mrs. Tiernan’s name. Nevertheless, the utility bills,
together with the check register, show that petitioner paid for
the gas, electric, and water for the condo in 2000.
Even if petitioner made a $2,000 financial contribution and
paid the utilities for the condo in 2000, the Court finds that
petitioner did not have such substantial continuing and
duplicative living expenses in Sacramento to justify the
allowance of a deduction for travel, meals, and lodging expenses
incurred while traveling. Respondent’s determination with
respect to petitioner’s employee expense deduction is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011