William D. and Betty J. Boyd - Page 3

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               Respondent determined a deficiency of $3,418 in petitioners’           
          Federal income tax for 1999.                                                
               The sole issue for decision is whether petitioners had a               
          “home to be away from” within the meaning of section 162(a)(2)              
          during 1999 entitling them to a deduction for employee business             
          expenses.                                                                   
               Prior to trial, petitioners failed to execute an agreed                
          stipulation of facts pursuant to Rule 91(a), whereupon respondent           
          filed a motion to show cause why proposed facts in evidence                 
          should not be accepted as established.  The response filed by               
          petitioners was not responsive to the Court’s order.  The Court,            
          accordingly, issued an order making the rule absolute declaring             
          the facts proposed by respondent established for purposes of this           
          case.  At the time petitioners filed their petition, they listed            
          an address at Nederland, Texas.                                             
               William D. Boyd (petitioner) is a licensed Pentecostal                 
          evangelist.  He does not have a church or a fixed base of                   
          operation for the conduct of his ministry.  He and his spouse               
          (Mrs. Boyd) travel throughout the United States in a recreational           
          vehicle and conduct religious services at churches for either a             
          few days or a few weeks.  Mrs. Boyd assists petitioner as a                 
          singer at each of their appearances.                                        
               Petitioners call Prentice, Mississippi, their home.                    
          Petitioners, however, do not own or rent any dwelling in                    






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