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affiliate of Purdue University from January 31, 1992, through the
years in issue.
Mr. Evan became eligible for long-term disability benefits
from Purdue University on or about June 18, 1992. Mr. Evan
received benefits under this plan from June 18, 1992, through the
years in issue.
During the years in issue, petitioners had four children.
During this period, Mr. Evan was the primary caregiver for the
two youngest children.
On petitioners’ Federal income tax return for 1997, Mr. Evan
listed his occupation as “Professor”, and Mrs. Evan listed her
occupation as “Claims Authorizer”. Petitioners claimed a
deduction for Schedule A unreimbursed employee expenses of
$26,900, consisting of travel expenses, union and professional
dues, and professional subscriptions, but reported no wages from
Purdue University or any other source for any services performed
by Mr. Evan as a professor. The only wages reported were from
Mrs. Evan’s work with the Social Security Administration.
Mr. Evan organized the Center for Real Estate Services,
Inc., and was its sole employee. Neither Mr. Evan nor the Center
for Real Estate Services, Inc., listed, showed, sold, or
facilitated the sale of any real estate or received any
remuneration for listing, showing, selling, or facilitating the
sale of any real estate from January 31, 1992, through the years
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