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In 1998, petitioner husband (Mr. Nwankwo) started his own
small trucking business by purchasing an 18-wheeler Mack truck.
Mr. Nwankwo, who was self-employed, operated his business by
contracting his services to other large trucking companies.
During the taxable years at issue, Mr. Nwankwo contracted with at
least three different trucking companies, picking up and
delivering loads in Pennsylvania, Delaware, Connecticut, New
York, and New Jersey. His work frequently had him on the road at
least 3 days a week, often with overnight stays away from home.
Petitioner wife worked for Sommerset Community Action Program, a
social services agency, on a part-time basis in 2002, and then on
a full-time basis in 2003. Petitioners have four minor children
at home.
In 1998 and 1999, respectively, Mr. Nwankwo’s parents,
Raphael and Caroline Nwankwo, arrived from Nigeria to live with
petitioners. Neither Raphael nor Caroline Nwankwo worked outside
of the home. In late January 2002, Raphael Nwankwo returned to
Nigeria where he immediately fell ill. Between February and
August of 2002, petitioners sent the elder Mr. Nwankwo
approximately $1,450 to cover his medical and incidental
expenses, and paid approximately $700 for his travel expenses.
During this time, Raphael Nwankwo sporadically received a state
pension from the Nigerian Government of approximately $60 a
month. This pension, and petitioners’ support, constituted 100
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