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revoked the job offer. Mr. Stephens continued to work for NWA in
Minnesota for 14 months, until March 2004.
Mr. Stephens’ position in Minnesota had no specific end
date. After Mr. Stephens was bumped from his position in
Georgia, no NWA position was available for him to return to in
Georgia. He was forced to bump other employees and work in a
different city to stay with NWA. Mr. Stephens expected to return
to Georgia as soon as a job became available in Georgia, with NWA
or otherwise, that he could obtain. NWA’s needs for mechanics in
Georgia as well as the choices of the other mechanics also
subject to the seniority system would influence the timing of Mr.
Stephens’ return to an NWA position in Georgia.
Mrs. Stephens and petitioners’ family members remained in
Georgia at the family residence while Mr. Stephens worked in
Minnesota. Mr. Stephens lived with his parents in Otsego,
Minnesota, while he worked in Minnesota. Mr. Stephens returned
to Georgia occasionally to visit his family.
Petitioners claimed they contributed some items to charity
in 2003.
Petitioners’ Return
Petitioners claimed deductions for certain expenses on
Schedule A, Itemized Deductions, on the joint return for 2003.
Respondent examined the return for 2003 and issued petitioners a
deficiency notice in which he disallowed many of the expense
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