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The issues remaining for decision2 are:
(1) Is petitioner entitled to deduct certain claimed amounts
as unreimbursed employee expenses? We hold that he is not.
(2) Is petitioner entitled to a claimed Schedule C net loss
with respect to a claimed restaurant business? We hold that he
is not.
(3) Is petitioner entitled to a claimed Schedule C net loss
with respect to a claimed personal digital assistant consulting
business? We hold that he is not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time petitioner filed the petition in this case, he
resided in Dallas, Texas.
During 2001, FedEx Worldwide Services, one of the FedEx
companies, employed petitioner full time as a worldwide account
manager. Pursuant to certain policies (FedEx policies),3 FedEx
Worldwide Services agreed to reimburse employees for reasonable
2On brief, petitioner lists as an issue: “Allowance of
ordinary losses from the sale of vehicles used in a trade or
business or held as income producing property.” However, peti-
tioner states on brief: “With regard to the loss on the sale of
the vehicles, although petitioner believes that a minimal loss
should be allowed, he will not challenge the findings of the
respondent on that specific issue.” We conclude that petitioner
has abandoned the issue of whether he is entitled to deduct as
losses under sec. 1231(a)(2) certain claimed losses from the sale
of certain vehicles.
3The FedEx policies applied to FedEx Worldwide Services and
at least one other FedEx company (viz., FedEx Express).
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Last modified: May 25, 2011