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Background
Some of the facts have been stipulated, and the stipulated
facts and accompanying exhibits are hereby incorporated by
reference into our findings. Petitioners, husband and wife,
resided in Chattanooga, Tennessee, when they filed their petition
in this case.
Petitioner Bobby Lorn Claborn (Mr. Claborn) is a mechanical
engineer. Mr. Claborn worked for ResourceTek LLC from January 1
to February 16, 2003, was unemployed for the following 8 months,
and then worked for RWE NUKEM Corporation from October 20, 2003,
through the end of that year.
While employed by RWE NUKEM Corporation, Mr. Claborn drove
to work each work day. The distance from his house in
Chattanooga, Tennessee, to the offices of RWE NUKEM Corporation
in Oak Ridge, Tennessee, is approximately 224 miles round trip.
Petitioners electronically filed a timely joint Form 1040,
U.S. Individual Income Tax Return, for the 2003 taxable year.
Petitioners chose to itemize their deductions and attached a
Schedule A, Itemized Deductions. The Schedule A reflected total
itemized deductions of $34,100, which included a charitable
contribution deduction of $2,775 and an “other miscellaneous”
deduction of $21,729.3
3 This represents the amount by which petitioners’
miscellaneous deductions exceeded 2 percent of their adjusted
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