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Billiards, Inc., one of the corporations in which petitioner owns
an interest.
Petitioner performed many duties for the corporations
including: (1) Frequently visiting the properties for
maintenance or general supervision; (2) traveling to Skate Palace
to assist in the operations of the roller skating rink; and (3)
traveling to schools and radio stations to market the roller
skating rinks. In the course of performing these duties,
petitioner incurred traveling expenses, entertainment expenses,
and other expenses that were not reimbursed by the corporations.
Petitioner could have received reimbursement for these expenses
from the corporations, but he failed to ask.
On his 1990 and 1991 Federal income tax returns, petitioner
claimed miscellaneous itemized deductions in the amounts of
$12,831 and $11,629, respectively. These amounts primarily
represent what petitioner characterized as unreimbursed employee
business expenses incurred on behalf of the corporations. The
1991 miscellaneous itemized deductions include expenditures in
the amounts of $579 for tax return preparation fees and $25 for a
real estate license.
In the notice of deficiency, respondent disallowed
petitioner's 1990 and 1991 claimed unreimbursed employee expenses
in the amounts of $11,404 and $11,050, respectively. For the
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