Christopher D. and Kristie M. Farran - Page 6

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          return and issued petitioners a deficiency notice in which he               
          disallowed many of the expenses.  Of the expenses still in                  
          dispute,2 petitioners assert they are entitled to claimed noncash           
          charitable contributions as well as unreimbursed employee                   
          business expenses.  The unreimbursed employee business expenses             
          petitioners claimed include expenses for Mr. Farran’s vehicle,              
          lodging, and meals while in Detroit, Chicago, and Boston as well            
          as expenses for Internet access, uniform cleaning, tools,                   
          depreciation of tools, personal property taxes, job searching,              
          supplies, parking, publications, cellular telephone, and                    
          education mileage.                                                          
               Petitioners timely filed a petition.                                   
               The parties resolved many of the disputed expenses before              
          trial.  We are asked to determine whether petitioners are                   
          entitled to deduct the remaining expenses.  We begin by                     
          considering whether Mr. Farran was away from home when he                   
          incurred expenses for his vehicle, meals, and lodging in Detroit,           
          Chicago, and Boston.                                                        

               2Respondent concedes that petitioners are entitled to deduct           
          State and local taxes, real estate taxes, a portion of personal             
          property taxes, home mortgage interest, tax preparation fees, a             
          portion of job search expenses including job search mileage                 
          expenses, job union mileage expenses, certain amounts for tools,            
          and union dues.  Petitioners concede that they are not entitled             
          to deduct cash contributions to charity and a portion of uniform            
          cleaning expenses.                                                          

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