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Petitioner moved three times during the years in issue--
twice in 1999 and once in 2000. During the first move, he
relocated in February 1999, from Savage, Minnesota, to Charlotte,
North Carolina, to work for Alcoa as a senior electrical
engineer. During the second move, petitioner relocated in
October 1999, from Charlotte, North Carolina, to either
Louisville, Kentucky, or Jeffersonville, Indiana, to work for
Tower Automotive.5 During the third move, petitioner moved to
Philadelphia, Pennsylvania, in August 2000, to begin law school.
Petitioner claimed a deduction for moving expenses of
$29,500 for 1999. For his first move in 1999, from Minnesota to
North Carolina, petitioner presented two documents, each entitled
“Moving Expense Statement”, that he submitted to Alcoa for
reimbursement.6 Such statements cover a period from April 1999
5 The record is unclear as to where petitioner actually
moved. At the time of trial, petitioner testified that he moved
from Charlotte, N.C., to an apartment in Louisville, Ky. His
testimony is inconsistent and does not correspond with all of the
documents in the record. For example, petitioner presented a
“Household Goods Descriptive Inventory” dated Oct. 19, 1999,
which indicates a “loading address” in Savage, Minn., and a
destination of Louisville, Ky. However, petitioner also provided
a receipt for cable installation on Oct. 30, 1999, for an
apartment in Jeffersonville, Ind. Moreover, Tower Automotive
listed petitioner’s address at Jeffersonville, Ind., on his Form
W-2, Wage and Tax Statement, for 1999.
6 Petitioner also presented a receipt dated July 13, 1999,
regarding furniture purchased in Charlotte, N.C., and numerous
receipts for car rentals in Charlotte, N.C., from late June 1999
to early October 1999. Petitioner, however, testified that he
stopped working for Alcoa in June 1999, when it terminated his
(continued...)
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