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the issue for decision is whether petitioners are entitled to
deduct education expenses incurred in 1994.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners resided in Chinook, Montana. At the
time of trial, George Warren (hereinafter, petitioner) was 62
years old.
In 1986, petitioner decided to pursue a career in the
ministry of the United Methodist Church (UMC). The rules for
each level of candidacy can be found in the UMC’s 1992 Book of
Discipline.2 There are various levels of candidacy. The levels,
in ascending order, are: (1) Certified candidate, (2) local
pastor, (3) associate member, (4) probationary member, and (5)
member in full connection. Petitioner will be unable to become a
member in full connection because of the time commitment, as
petitioner will be forced to retire at the age of 70.
2 The 1992 Book of Discipline is applicable to the year in
issue. These rules changed in 1996.
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