Ronald Z. Thompson - Page 2

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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                 

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