James M. and Ruth J. Riley - Page 28

                                       - 27 -                                         
               As previously stated, respondent has conceded that                     
          petitioners have substantiated and may deduct travel expenses for           
          fuel, food, and lodging totaling $391.14 for 2001, $940 for 2002,           
          and $385.01 for 2003.                                                       
               Respondent’s concession that petitioners have substantiated            
          these expenses is a concession that petitioner incurred the                 
          expenses while he was away from home on business.  Petitioners              
          substantiated those expenses with receipts and bank statements              
          provided to respondent and entered into the record of this case.            
          The receipts and bank statements show purchases that petitioner             
          made in States other than Utah dated as follows:                            
                 Date                 Source                 State                    
                 4/22/2001     Statement                 Wyoming                      
                 4/24/2001     Statement                 Wyoming                      
                 4/25/2001     Receipt/Statement         Wyoming                      
                 4/26/2001     Receipt/Statement         South Dakota                 
                 4/28/2001     Receipt/Statement         Minnesota                    
                 5/3/2001      Receipt                   Iowa                         
                 5/10/2001     Receipt                   Minnesota                    
                 5/16/2001     Receipt                   Minnesota                    
                 5/23/2001     Receipt                   Iowa                         
                 5/30/2001     Receipt                   Minnesota                    
                 6/3/2001      Receipt                   Minnesota                    
                 6/5/2001      Receipt                   Minnesota                    
                 6/7/2001      Receipt/Statement         Minnesota                    
                 6/14/2001     Receipt                   South Dakota                 
                 6/15/2001     Receipt                   Nebraska                     
                 6/16/2001     Receipt/Statement         Minnesota                    
                 6/17/2001     Receipt                   Wyoming                      
                 9/5/2001      Receipt/Statement         Wyoming                      
                 9/6/2001      Receipt/Statement         Wyoming                      
                 9/6/2001      Statement                 South Dakota                 
                 9/7/2001      Receipt                   Minnesota                    
                 9/10/2001     Statement                 Minnesota                    
                 9/15/2001     Receipt/Statement         Minnesota                    




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