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Revenue Code applicable to the relevant years. Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
The parties have stipulated some of the facts. We
incorporate herein by this reference the parties’ stipulation of
facts and the exhibits submitted therewith. We find the
stipulated facts accordingly. Petitioner is a well-educated man
whose college degrees include a bachelor’s degree in electrical
engineering (telecommunications), a master’s degree in business
administration (business management), and a doctor’s degree in
electrical engineering. He resided in Vienna, Virginia, when his
petition was filed. He filed 1994 and 1995 Federal income tax
returns using the filing status of “Married filing separately”.
During the subject years, petitioner worked full time for
GTE, Inc. (GTE), as a director of research and the manager of its
research and development facility in Waltham, Massachusetts
(Waltham).1 He generally worked for GTE a minimum of 40 hours
per week, staying at his residence in Waltham during the week
(unless away from Waltham traveling on GTE business) and staying
at his wife’s principal residence in Vienna, Virginia, on the
1 GTE paid to petitioner in each of the subject years a
salary of approximately $200,000. In part because of his
supervisor’s perception that petitioner worked “long hours” for
GTE during the subject years, petitioner was later promoted to
vice president.
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