John Michael Kernan - Page 3

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               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 project           

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