3
employment contract before each tour. While traveling,
petitioner received a per diem allowance of $30 for expenses.
When petitioner was on tour he stayed in hotel rooms with
other employees. When not on tour petitioner stayed at his
parents' house in Boise, Idaho, where he kept his car, dog, and
other belongings. He was registered to vote, was licensed to
drive, and paid State income tax in Idaho. Petitioner had no
ownership interest in his parents' house and paid no rent. He
did perform some work around the house when he was not traveling,
including painting, electrical repairs, installing light fixtures
with motion sensors, landscaping, and constructing a dog house.
Petitioner's sole financial contribution to the household
consisted of approximately $500 paid to obtain the supplies
needed to perform these activities.
On his 1990 Federal income tax return, petitioner claimed
deductions totaling $14,021 for expenses incurred while traveling
on the tours. In the notice of deficiency respondent determined
that petitioner was not entitled to deduct the traveling expenses
because petitioner was not "away from home". Petitioner contends
that these expenses are properly deductible as traveling expenses
while away from home pursuant to section 162(a)(2), because his
home was his parents' house in Boise, Idaho, and his employment
was temporary.
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011