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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