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At all relevant times, including throughout 2002 and at the
time they filed the petition in this case, petitioners resided in
Keyser, West Virginia (Keyser). Mr. Shoemaker lived in Keyser,
where he grew up, for personal reasons; he liked living in
Keyser, and he wanted to raise his family there.
During 2002, Mr. Shoemaker, an electrician, was employed as
a subforeman by Freestate Electrical Construction Company
(Freestate) located in Beltsville, Maryland. On each day Mr.
Shoemaker worked for Freestate during 2002, he drove in the
morning from petitioners’ residence in Keyser to a job site (job
site location) and returned in the evening to petitioners’
residence.
Petitioners filed a tax return for their taxable year 2002
(petitioners’ 2002 return). In Schedule A-Itemized Deductions
included as part of that return (2002 Schedule A), petitioners
claimed, inter alia, certain unidentified “Job Expenses and Most
Other Miscellaneous Deductions” (job expenses) totaling $35,558
prior to the application of the two-percent floor imposed by
section 67(a).
As required by section 67(a), petitioners reduced the
$35,558 of total job expenses claimed in the 2002 Schedule A by
two percent of their adjusted gross income (i.e., by $1,946). In
determining the taxable income reported in petitioners’ 2002
return, petitioners deducted the balance (i.e., $33,612), as well
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