Robert A. White - Page 3

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          Revenue Code in effect for the year in issue, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
               Respondent determined a deficiency of $6,175 in petitioner’s           
          2003 Federal income tax.  After a concession,1 the issue for                
          decision is whether petitioner is entitled to certain deductions            
          claimed on Schedule A, Itemized Deductions.                                 
               Some of the facts have been stipulated and are so found.  We           
          incorporate the stipulation of facts and attached exhibits herein           
          by this reference.  At the time the petition was filed,                     
          petitioner resided in Fort Washington, Maryland.                            
               Petitioner was a staff sergeant in the National Guard and              
          also worked as a customs and immigration inspector for the U.S.             
          Immigration and Naturalization Service (INS).  After a                      
          reorganization, petitioner was employed by the Department of                
          Homeland Security (DHS) during tax year 2003.2  DHS stationed               
          petitioner at points of entry to inspect persons entering the               
          country.  Petitioner’s regular duty location was the Baltimore              

               1 Respondent conceded that petitioner is not liable for                
          $1,178 identified in the notice of deficiency as “uncollected               
          FICA tax”.  Respondent has failed to provide an explanation as to           
          this adjustment.                                                            
               2 The Court notes that on Mar. 1, 2003, the Department of              
          Homeland Security absorbed the U.S. Immigration and                         
          Naturalization Service (INS).  Thereafter, a new organization               
          called U.S. Customs and Border Protection combined INS                      
          inspectors, Border Patrol, and Customs inspectors.  See 6 U.S.C.            
          251 (Supp. II, 2002).                                                       

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