- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011