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Respondent determined a deficiency in petitioners' 1991
Federal income tax in the amount of $2,971. The issue for
decision is whether petitioners are entitled to deductions for
"away from home" expenses pursuant to section 162(a)(2).
Some of the facts have been stipulated and are so found.
Petitioners resided in Houston, Texas, at the time they filed
their petition. For clarity and convenience, the findings of
fact and opinion have been combined.
Petitioner Elizabeth H. Turner (petitioner) was a college
professor. She taught United States history with a special
emphasis on the study of nineteenth and twentieth century
southern women.
From 1979 to 1982, petitioner taught history at Queens
College in Charlotte, North Carolina. Petitioners owned a house
in Charlotte, North Carolina, where they lived from January 1,
1974, through July 1, 1982. In 1982, petitioners moved from
Charlotte, North Carolina, to Houston, Texas. At that time, they
leased the house in Charlotte to tenants at least to the date of
trial.
Petitioners moved to Houston, Texas, because petitioner-
husband accepted a job in Houston and so that petitioner could
pursue her doctorate degree in history at Rice University,
Houston, Texas. Petitioner received her Ph.D. in history from
Rice University in 1990.
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