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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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