Darryl R. and Kristi L. Stephens - Page 3




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          other court, and this opinion shall not be treated as precedent             
          for any other case.                                                         
               Respondent determined a $3,323 deficiency in petitioners’              
          Federal income tax for 2003.  After concessions,2 we are asked to           
          decide two issues.  First, we are asked to decide whether                   
          petitioner Darryl R. Stephens (Mr. Stephens) was away from home             
          when he worked as an airline mechanic for Northwest Airlines                
          (NWA) in Minnesota to determine whether petitioners are entitled            
          to deduct expenses for his vehicle and meals while he was away              
          from Georgia where he normally lived.  We conclude he was not               
          away from home.  Second, we are asked to decide whether                     
          petitioners substantiated a claimed noncash charitable                      
          contribution.  We conclude that petitioners have not                        
          substantiated the contribution and are therefore not entitled to            
          a noncash charitable contribution deduction.                                
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          Petitioners resided in Fayetteville, Georgia, at the time they              
          filed the petition.                                                         
          Mr. Stephens’ Employment With Northwest Airlines                            
               Mr. Stephens began as an airline mechanic for NWA in 1988.             
          Petitioners moved to Georgia in 2002, and Mr. Stephens continued            
          working for NWA in Georgia.                                                 


               2See infra note 3 for the concessions each party made.                 





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