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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies of $4,964, $5,482, and
$6,077 in petitioners’ 2002, 2003, and 2004 Federal income taxes
respectively.1 The issues for decision are whether petitioners
are entitled to (1) itemized deductions in amounts greater than
the standard deductions allowed by respondent for the years in
issue and (2) a credit for education expenses in 2003 and 2004.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits, as well as
additional exhibits introduced at trial, are incorporated herein
by this reference. Petitioners resided in Orlando, Florida, when
the petition was filed.
During the years at issue, Patricia R. Williams was an
engineer with the Florida Department of Environmental Protection
and James L. Williams was a salesman. For approximately the
first 9 months of 2002, Mr. Williams worked for U.S. Foods
selling food products in central Florida. Mr. Williams spent the
majority of his time at work visiting customers and soliciting
business. U.S. Foods did not provide an automobile for Mr.
Williams to use, nor did it reimburse him for gasoline or other
expenses.
1 All dollar amounts are rounded to the nearest dollar.
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Last modified: November 10, 2007