- 2 - The sole issue for decision is whether petitioner is entitled to deductions under section 162(a)(2) for expenses while away from home for the year 1996. Some of the facts were stipulated. Those facts and the accompanying exhibits are so found and are incorporated herein by reference. Petitioner's legal residence at the time the petition was filed was Dallas, Texas. Petitioner is a certified public accountant in the State of Texas. For the year at issue, petitioner was a consultant specializing in the implementation of computer systems and, in particular, a software application known as "Oracle Financials". He conducted this work as a self-employed trade or business activity that he reported on his Federal income tax return for 1996 on Schedule C, Profit or Loss From Business. From the time of his graduation from Texas A & M University at College Station, Texas, in 1990, petitioner lived at Austin, Texas. He was employed for approximately 2 years by a nationally recognized accounting firm and thereafter was employed by the Texas Workers' Compensation Insurance Fund (the Fund) at Austin, Texas. Sometime during March 1996, petitioner's superior or supervisor at the Fund obtained employment with Josten's, Inc. (Josten's) at Memphis, Tennessee. Through the efforts or assistance of his former supervisor, petitioner was interviewed at Josten's for the specific purpose of teaching Josten's projectPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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