Ann Jorgensen - Page 2

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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.                  
               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                  

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Last modified: May 25, 2011