Jozsef and Zsuzsanna Balla - Page 6




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               On their 2003 return, petitioners claimed and respondent               
          disallowed the following itemized deductions under Job Expenses             
          and Most Other Miscellaneous Deductions:                                    
               Unreimbursed employee expenses          $16,173                        
               Tax preparation fees                    595                            
               Other expenses--Sailor Req’d Phone/Pager  1,282                        
          Petitioners again attached a Sailor Travel Statement to their               
          2003 return to substantiate their claim to unreimbursed employee            
          expenses for that year.  It included the Supplemental Tug/Barge             
          Sailor Travel Schedule reproduced below, the same authorities as            
          they had attached to their 2002 return, a 2003 port list for the            
          Yabucoa vessel, and a schedule listing ports where petitioner               
          purportedly was stationed on particular dates in 2003.  The                 
          Supplemental Tug/Barge Sailor Travel Schedule, with original                
          emphases, that petitioners attached to their 2003 return is                 
          reproduced in part below:                                                   
               Taxpayer is a Merchant Sailor assigned to work aboard a Tug Boat       
               traveling between ports located on the Atlantic Ocean and              
               therefore qualifies per attached Rev Proc 2002-63’s                    
               “Transportation Industry Employees” and attached MARIN JOHNSON TAX     
               COURT DECISION & IRS Publication 463 (Chapter 1 Page 5) to compute     
               his DEEMED SUBSTANTIATED Out-of-Town Travel Costs by using             
               attached Pub 1542’s Foreign OCONUS Rates and Domestic CONUS Rates      
               for EACH CITY as follows:                                              















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