Elizabeth H. and Albert B. Turner - Page 4

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               On November 5, 1990, while petitioner was employed at Queens           
          College, she applied for employment at the University of Alabama            
          at Birmingham and the University of South Alabama.  On                      
          November 18, 1990, petitioner applied for a position as Assistant           
          Professor of History at the University of Houston-Downtown,                 
          Houston, Texas.  Petitioner was not offered a position by either            
          university in Alabama.                                                      
               In mid-March 1991, petitioner was offered employment by the            
          University of Houston-Downtown.  By a May 10, 1991, letter from             
          the president of Queens College, petitioner was offered a                   
          continued appointment as Assistant Professor of History for the             
          1991-1992 academic year.  On May 13, 1991, the president of the             
          University of Houston-Downtown formally offered her a position.             
          Petitioner accepted the offer from the University of Houston-               
          Downtown.                                                                   
               On their 1991 Federal income tax return, petitioners claimed           
          deductions related to petitioner's employment in Charlotte, North           
          Carolina, in the amount of $9,586, as follows:                              
               Rent                $ 2,438                                            
               Electricity         665                                                
               Phone               784                                                
               Auto Expenses       862                                                
               Maintenance         360                                                
               Food           3,120                                                   
               Postage        99                                                      
               Return to Houston   1,158                                              
               Food                  100                                              
               Total                 9,586                                            






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