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The issues for decision are: (1) Whether petitioner is
entitled to deduct the expense of flight school as an educational
expense under section 162(a); and (2) whether petitioner is
liable for the accuracy-related penalty under section 6662(a).
FINDINGS OF FACT
The parties’ stipulation of facts and the attached exhibits
are incorporated herein by this reference, and the facts
stipulated are so found. At the time the petition was filed,
petitioner resided in Castro Valley, California.
Petitioner graduated from San Jose State University with a
bachelor of science degree in aviation operations. Petitioner is
currently employed as an aeronautical engineer2 with Planners
Collaborative, Inc. (Planners), a subcontractor which provided
engineering and technical management services to support the
National Aeronautics and Space Administration’s (NASA) Ames
Research Center. Prior to his employment with Planners, from
August 2000 through October 2004, petitioner was employed as an
aeronautical engineer with Teculan Inc. (Teculan), a
subcontractor which also provided engineering and technical
management services to NASA.
2 The parties also referred to petitioner as a systems
engineer.
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Last modified: November 10, 2007