James L. and Patricia R. Williams - Page 3




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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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