-3-
During 1991, Paramax had in effect a policy that would have
allowed Mr. Bradley to be reimbursed for all of his travel
between the two locations at the rate of 27 cents per mile.
Mr. Bradley, however, did not file a claim for reimbursement with
Paramax and was not reimbursed for any of his travel between the
two locations. Instead, he claimed a $9,143 deduction for
unreimbursed employee business expenses on Schedule A and Form
2106 (Employee Business Expenses) attached to petitioners' 1991
Form 1040. Mr. Bradley calculated the deduction by taking the
product of his actual vehicle expenses for 1991 and the business
use percentage of his automobile. The deduction was calculated
as follows:
Expenses
Gasoline, oil, repairs, vehicle insurance, etc. $2,787
Lease payments on a 1991 Infiniti, Model Q45 10,090
Total 12,877
Multiplied by business use percentage 171%
Vehicle expense claimed 9,143
1Business use percentage = 9,968 business use miles / 14,039
total miles = 71%.
During the first 6 months of 1991, petitioner Emma Bradley
was employed as a nurse at Friendswood Medical Arts (Friendswood)
in Friendswood, Texas. Friendswood did not require Mrs. Bradley
to travel as part of her duties. During the last 6 months of
1991, Mrs. Bradley was employed as a nurse at Gastroenterology
Consultants (Gastroenterology) in Houston, Texas. Mrs. Bradley
was required to use her own car to travel between offices as part
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