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After concessions,1 the issue for decision is whether
petitioners are entitled to deduct Schedule A “away from home”
expenses of $23,149, $36,402, and $22,532, for 1994, 1995, and
1996, respectively.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time their
petition was filed, petitioners resided in Rowland Heights,
California.
From January through April of 1994, Vladimir Saric
(petitioner) was unemployed. He lived in Rowland Heights with
his wife and three daughters. Through CDI Corp. or CDI Personal
Services, Inc. (collectively referred to as CDI), a temporary
employment agency, petitioner was assigned to work for Raytheon
Service Co. (Raytheon) as an electrical engineer for a Federal
Aviation Administration (FAA) project. Raytheon’s office is
located in Manhattan Beach, California. In obtaining the job
with Raytheon, petitioner was interviewed by Harry Moreau (Mr.
Moreau), an engineer with FAA who was overseeing a project in
Fremont, California (the Fremont project). The objective of the
project was to install two diesel generators which would provide
1 The parties submitted a Stipulation of Settled Issues in
which petitioners conceded all issues except for the issue stated
above.
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