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During the years in issue, petitioner worked as a contract
engineer through an agency named TAD Technical. As a contractual
engineer, petitioner does not have an opportunity to work as a
permanent employee and does not receive holiday, vacation, or
severance pay. The usual contract term is from 3 to 6 months.
In 1992 and 1993, petitioner worked as a software quality
engineer for Texas Instruments in Lewisville, Texas. Petitioner
began work on March 11, 1992, and initially contracted to work
for Texas instruments for only 6 months; however, after the first
6-month period, his contract was later extended for an additional
6-month period. After the second 6-month period, the contract
was extended again until December 17, 1993.
While working for Texas Instruments, petitioner rented a
small 1-bedroom apartment and incurred various associated
expenses during the 1992 and 1993 tax years. Petitioners'
children continued to live in Lawrenceville, Georgia, where the
children also attended school. Mrs. Johnson worked in the
Atlanta area. Petitioner usually drove home once a month to
visit his family.
On their Federal income tax return for the 1993 tax year,
petitioners claimed unreimbursed employee expense deductions in
the amount of $19,218, representing expenses incurred by
petitioner while working for Texas Instruments. In a notice of
deficiency dated May 1, 1997, respondent disallowed $17,727 of
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