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GARDIN v. COMMISSIONER

Docket No. 1903-74.

64 T.C. 1079 (1975)

RONALD L. GARDIN AND CECELIA A. GARDIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 24, 1975.

Attorney(s) appearing for the Case

Douglas H. Clark, Jr., for the petitioner.

Richard A. Jones, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $975 in petitioners' Federal income taxes for 1971. The sole issue presented is whether expenses paid by petitioner Ronald L. Gardin, a professional football player, for food and lodging at his employers' franchise locations were incurred while he was "away from home in the pursuit of a trade or business."1

FINDINGS OF FACT

Ronald L. and Cecelia A. Gardin...

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