George W. Warren and Florence J. Winterheld - Page 2

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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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