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Petitioner wife and petitioners' two children continued to
live in Arlington while petitioner lived in New Braunfels.
Petitioner wife did not want to live in New Braunfels. She
thought petitioner's apartment was too small and her sleep was
disturbed by nightly train traffic. Furthermore, because
petitioners' sons were attending high school in Arlington,
petitioners wished to remain in Arlington until their sons
graduated.
In early 1995, petitioner gave Motorola oral notice that he
would be leaving. Petitioner had secured a job at Dell Computers
in Austin, Texas, and decided to leave Motorola after he
completed his current project. Petitioner left Motorola on
February 10, 1995.
Petitioner moved to Austin, Texas, to work for Dell
Computers in February of 1995. Petitioner's family did not
initially move with petitioner to Austin because petitioner wife
was working in Arlington and petitioners' sons were still in high
school. Petitioner wife moved to Austin in April 1995 shortly
before petitioners' youngest son graduated from high school.
Petitioners' youngest son lived with a friend in Arlington for 2
months until his high school graduation.
On their 1994 Federal income tax return, petitioners claimed
unreimbursed employee expenses in the amount of $16,150, less the
2-percent AGI floor of $1,027, or $15,123. Petitioners reported
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