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A, Itemized Deductions, for the years in issue; and (2) whether
petitioners are entitled to deductions for expenses claimed on
Schedule C, Profit or Loss from Business, for the years in issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. Amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been deemed stipulated pursuant to
Rule 91(f) 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
Valparaiso, Indiana.
Mr. Evan obtained a bachelor of arts degree in economics and
business administration, a master of arts degree in economics, a
bachelor of business administration degree in management, and a
doctor of philosophy degree in management.
Mr. Evan taught business courses at Purdue University but
was denied tenure there in April 1991. Mr. Evan subsequently
received a Notice of Non-Renewal of Contract with Purdue
University on April 29, 1991. Mr. Evan’s employment with Purdue
University expired on June 30, 1992. Mr. Evan did not teach any
courses or provide any other services to Purdue University or any
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