Thomas E. and Susan L. Truskowsky - Page 3

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          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           
               Respondent determined deficiencies in petitioners' Federal             
          income tax of $17,656 for 1996 and $19,849 for 1997.  The issue             
          for decision is whether petitioners' business losses constitute             
          passive activity losses.  The amount of petitioners' allowable              
          itemized deductions and personal exemptions will be determined by           
          our disposition of the contested issue.                                     
               The stipulated facts and exhibits received into evidence are           
          incorporated herein by reference.  At the time the petition in              
          this case was filed, petitioners resided in Moatsville, West                
          Virginia.                                                                   
                                     Background                                       
          Petitioners' Vocations                                                      
               During the years 1996 and 1997, petitioners resided in                 
          Trappe, Pennsylvania, and both were full-time employees at a                
          large computer software corporation, the Oracle Corporation                 
          (Oracle).  Petitioner Susan Truskowsky was a program manager in             
          the Program Management Group at Oracle Consulting.  Her job                 
          required her to travel to projects around the country, mostly in            
          the Mid-Atlantic region and to Dallas, Texas.  In 1996,                     
          petitioner Thomas Truskowsky was employed as senior principal               
          consultant for Oracle.  In 1997 he became a technical manager.              








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