Christopher D. and Kristie M. Farran - Page 5

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               Petitioners maintained Internet access at the Minnesota                
          residence for the whole year.  Mr. Farran used the Internet when            
          he was in Minnesota to search for a job and to monitor                      
          investments, but no other family member used it.  Mr. Farran also           
          incurred some other costs, such as for resume paper, in his job             
          search.  Mr. Farran also had a cellular phone during 2003 that he           
          acknowledged using for personal calls.  Mr. Farran’s family moved           
          to Georgia at a date not evident in the record and lived in                 
          Georgia at the time of trial.                                               
               Mr. Farran used some of his own tools in his work for NWA.             
          Mr. Farran also wore a uniform while he worked for NWA.  He                 
          generally wore one shirt per day and cleaned his clothing in a              
          washing machine.  Mr. Farran estimated that he worked                       
          approximately 22 days per month for NWA.                                    
               Petitioner Kristie Farran (Mrs. Farran) was a substitute               
          teacher during 2003.  Mr. and Mrs. Farran donated a 1989 Pontiac            
          Sunbird with a Kelley Blue Book value of $1,750 to Volunteers of            
          America, Inc. in April 2003.  Volunteers of America later sold              
          this vehicle in “as is” condition for $40.  Mr. and Mrs. Farran             
          contributed some items to Goodwill and also bought items for                
          their children’s school during 2003.                                        
          Petitioners’ Return                                                         
               Petitioners claimed certain expenses on Schedule A, Itemized           
          Deductions, on the return for 2003.  Respondent examined the                

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