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the meaning of section 274(m)(2) or whether she had ordinary and
necessary employee business expenses for travel and education
under section 162.1
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioner resided in San
Francisco, California, at the time she filed her petition.
Background
Petitioner teaches English at Abraham Lincoln High School, a
culturally diverse San Francisco public high school with a
predominantly Asian student population. During 1995 and 1996,
petitioner also was the chair of the high school's English
department. Most of petitioner's students are immigrants or have
parents who are immigrants.
As a teacher in the San Francisco Unified School District,
petitioner has a mission to promote both intellectual growth and
cultural and linguistic sensitivity to enable students from all
cultural backgrounds to succeed. Petitioner's duties as a
teacher include, among others, to be competent in her subject
field, to be involved in the development and implementation of
curriculum, to demonstrate a repertoire of teaching strategies
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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