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Respondent determined deficiencies of $2,435 and $3,545
in petitioners’ Federal income taxes for 1995 and 1996,
respectively. The issues for decision for each year in issue
are: (1) Whether petitioners are entitled to various deductions
claimed on a Schedule C; and (2) whether petitioners are entitled
to a charitable contribution deduction greater than the amount
allowed by respondent.
Background
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. At the time the petition was
filed, they resided in Dayton, Ohio. References to petitioner
are to Roger F. Ellis.1
Petitioner holds undergraduate and graduate degrees in
electrical engineering. In 1989, at the age of 44, after 21
years of military service, petitioner retired from the United
States Air Force (USAF). While in the USAF, petitioner was
involved in the acquisition of missiles, aircraft, and, as he
testified at trial, “things of that type”. His military
assignments also included flight and systems tests.
Shortly after retiring from the military, petitioner began
1 Carolyn R. Ellis neither signed the stipulation of facts
nor appeared at trial. The case will be dismissed as to her for
lack of prosecution. The decision to be entered with respect to
her will reflect the disposition of the issues considered in this
opinion, as well as those issues agreed upon by respondent and
petitioner.
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