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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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