Jozsef and Zsuzsanna Balla - Page 3




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          Hornbeck also provided petitioner with uniforms and safety                  
          equipment (including work vest, hard hat, safety goggles, safety            
          glasses, rain slicker, and flashlight) that it required for its             
          employees.  Petitioner was also required to wear steel-toe boots,           
          which were not provided by Hornbeck.  Hornbeck did not provide or           
          require its employees to have cell phones or pagers.                        
               In April 2002, petitioner attended a firefighting school in            
          Fort Lauderdale, Florida.  Hornbeck did not require or pay for              
          petitioner to attend the firefighting school; rather,                       
          petitioner’s tuition was paid by his union.  He drove his own car           
          to Fort Lauderdale from his home in Sarasota to attend the                  
          firefighting school.  Petitioner recorded the dates, location,              
          and purpose of his trip to Fort Lauderdale on his personal                  
          calendar for 2002.  He did not keep any record regarding the                
          mileage traveled on his trip to the firefighting school, but the            
          parties have agreed that the one-way trip from petitioner’s home            
          in Sarasota to Fort Lauderdale is approximately 209 miles.                  
               Under Job Expenses and Most Other Miscellaneous Deductions             
          on their Schedule A, Itemized Deductions, for 2002, petitioners             
          claimed the following deductions:                                           
                    Unreimbursed employee expenses     $18,509                        
                    Tax preparation fees               1,190                          
                    Other expenses                     3,143                          
          Respondent allowed the deduction for tax preparation fees in                
          2002.  Petitioners also attached an extensive compilation of                







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