Scott Owen Schubert & Amy K. Moore - Page 4

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          subcontractor for Comcast.  As a subcontractor, Mr. Schubert                
          traveled to customers’ residences and disconnected the customers’           
          cable for failure to pay their Comcast bills.  Mr. Schubert was             
          unemployed for the remainder of 2003.                                       
               Ms. Moore worked as a real estate agent for Intero Real                
          Estate Services and as an administrator for Superior Employment,            
          Inc.  Ms. Moore showed properties to clients, transported                   
          transactional documents, and performed other errands in San Jose,           
          Santa Clara, and Palo Alto, California.                                     
               Petitioners timely filed a joint Form 1040, U.S. Individual            
          Income Tax Return, for 2003.  Petitioners reported $55,955 as               
          compensation for services ($13,687 for Mr. Schubert and $42,268             
          for Ms. Moore).  On petitioners’ Schedule A, Itemized Deductions,           
          they claimed a $75 deduction for their tax preparation materials            
          and the following unreimbursed employee expenses:                           
          Category                    Mr.Schubert          Ms. Moore                  
               Vehicle expense        1$12,884             1$12,312                   
               Parking, tolls,          625                 550                       
               Travel expense           1,650               1,300                     
              away from home                                                         
               Meals and                550                 650                       
               Business expense         4,725               11,175                    
               Total                    220,434             225,987                   
               1  Based on a 36-cent standard mileage rate.                           
               2  Before application of the sec. 67(a) 2-percent floor.               
               Respondent disallowed petitioners’ deductions for                      
          unreimbursed employee expenses and tax preparation materials.               

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Last modified: March 27, 2008