-2-
$2,756 and $3,162.40, respectively.1 After concessions by the
parties, we decide whether petitioners substantiated their
deductions for self-employment expenses, personal property tax,
student loan interest, noncash charitable contributions, job-
related mileage, and tuition. We hold they did not. We also
decide whether petitioners are liable for accuracy-related
penalties determined by respondent under section 6662(a). We
hold they are.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulated
facts and the exhibits submitted therewith are incorporated
herein by this reference. Petitioners are husband and wife, and
they filed joint 2000 and 2001 Federal income tax returns. They
resided in Colorado Springs, Colorado, when they filed their
petition with the Court.
During 2000 and 2001, Roy Oswandel (petitioner) worked full
time for the U.S. Postal Service. In 2001, he also worked part
time for two other employers, neither of which was a church.
Petitioner is an ordained minister and before the years in
issue worked in the military as a chaplain. After leaving the
military, he continued to perform ministerial duties. These
duties included officiating weddings, holding retreats, and
1 Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
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