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to look for employment as a technical consultant or engineering
manager for private sector defense contractors. During the years
in issue, petitioner’s search for employment included driving to,
or otherwise contacting, numerous companies that might have a
need for the types of services he offered. Petitioner apparently
worked for a time during 1991, but after that he remained
unemployed until January 1999 when he was offered and accepted
employment as a civilian engineer with the USAF.
Petitioner’s records indicate that, in connection with his
search for employment, he visited the offices of Modern
Technologies Corp. in Dayton, Ohio, numerous times, perhaps as
often as once a month, during 1995. In response to an inquiry
made by respondent’s agent during the examination, that company
indicated that petitioner had not made any contacts with it
regarding employment during 1995 or 1996.
Petitioners have three daughters. During the years in
issue, one attended college in Birmingham, Alabama; one attended
college in Williamsburg, Kentucky; and the third was employed in
Columbia, Missouri. Three or four times each year, petitioner or
petitioners traveled to those cities where one of their daughters
was living.
Petitioners are, and were during the years in issue, active
members of the First Baptist Church of Fairborn, Ohio (the
Church). Carolyn R. Ellis was employed as a secretary by the
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