James O. Henderson - Page 2

                                          2                                           
               Respondent determined a deficiency in petitioner's Federal             
          income tax for 1990 in the amount of $1,791.  At the time the               
          petition was filed, petitioner resided in Las Vegas, Nevada.                
               After concessions,2 the issue is whether petitioner is                 
          entitled to deduct expenses for travel "while away from home"               
          pursuant to section 162(a)(2).                                              
                                  FINDINGS OF FACT                                    
               James O. Henderson (petitioner) graduated from college in              
          June 1989 majoring in theatrical arts.  Immediately after                   
          graduation petitioner was employed by the Oregon Shakespeare                
          Festival for 6 months.  During 1990, petitioner was employed as a           
          lighting technician for Walt Disney's World on Ice (World on                
          Ice).  World on Ice had its headquarters in Virginia; however,              
          the show toured, stopping in various cities for brief periods of            
          time.  Petitioner traveled on three tours during 1990.  The first           
          tour lasted from January 1 to May 13, 1990, and included stops in           
          19 cities in 10 States.  The second tour ran from July to                   
          November 1990 and consisted of shows exclusively in Japan.  The             
          third tour lasted from December 5 to December 31, 1990, and                 
          included stops in Washington, Montana, and North Dakota.                    
          Petitioner was employed on a tour by tour basis, signing a new              




          2   Respondent concedes that petitioner is entitled to a                    
          deduction in the amount of $2,685 for miscellaneous expenses on             
          Schedule A.                                                                 




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