Raymond J. and Maria V. Zbylut - Page 2




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               (1) Whether for the years in issue petitioners may deduct at           
          Federal per diem rates meal expenses that Raymond J. Zbylut                 
          (petitioner) did not pay or incur;                                          
               (2) whether petitioners are entitled to deductions for                 
          expenses related to petitioner’s travel to union halls in 2002;             
          and                                                                         
               (3) whether petitioners are entitled to deductions claimed             
          for other job-related expenses in 2002.                                     
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioners resided in Nebraska at the time they filed their                
          petition.                                                                   
               Petitioner was employed as a merchant sailor at various                
          times in 2002 by American Ship Management, L.L.C. (American                 
          Ship), and by Matson Navigation Co. (Matson Navigation).  During            
          that year, American Ship provided meals and lodging without cost            
          to petitioner whenever he was on active status and assigned to a            
          vessel for that company.  Petitioner worked for American Ship               
          aboard a container vessel called the President Wilson for                   







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