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when he worked as an airline mechanic for Northwest Airlines
(NWA) in Newark to determine whether petitioners are entitled to
deduct expenses for his vehicle, meals, and lodging while Mr.
Riley was away from Prescott, Wisconsin, in the Minneapolis area
where he normally lived. We conclude that Mr. Riley was not away
from home. Second, we are asked to decide whether petitioners
substantiated various other expenses. We conclude that
petitioners have substantiated and are entitled to deduct some of
these other expenses.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Prescott, Wisconsin, at the time they
filed the petition.
Mr. Riley’s Employment With Northwest Airlines
Mr. Riley began as an airline mechanic for NWA in 1992 and
worked through at least 2004.3 Mr. Riley worked in Minneapolis
from 1992 through April 2003.
NWA sent layoff notices to some of its employees when it
experienced financial difficulties. The employees receiving the
notices could either choose to accept the layoff or exercise
2All section references are to the Internal Revenue Code in
effect for 2003, and all Rule references are to the Tax Court
Rules of Practice and Procedure, unless otherwise indicated.
3There is nothing in the record to indicate whether Mr.
Riley has continued to work for NWA after his 14-month job in
Newark ended in 2004.
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