Harry T. Cavalaris - Page 14

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               On the morning of February 21, 1990, petitioner flew to                
          Atlanta, Georgia, for a diocese meeting.  Petitioner returned to            
          his home in Charlotte, North Carolina, later that evening.                  
          Because the trip did not require sleep or rest, petitioner is not           
          entitled to a deduction for meals on this trip.  Accordingly, the           
          meal expenses claimed in the amount of $25, listed in paragraph             
          17 of the stipulation of facts, are not deductible.  See United             
          States v. Correll, supra; Saltzman v. Commissioner, supra at 725;           
          sec. 1.170A-1(g), Income Tax Regs.                                          
               Respondent asserts that some expenses were lavish or                   
          extravagant and that some expenses were not required to be paid             
          by petitioner.  Both assertions raise the question whether the              
          expenses were reasonable and/or necessary.  Section 1.170A-1(g),            
          Income Tax Regs., provides, in relevant part:                               
               Similarly, out-of-pocket transportation expenses necessarily           
               incurred in performing donated services are deductible.                
               Reasonable expenditures for meals and lodging necessarily              
               incurred while away from home in the course of performing              
               donated services also are deductible.                                  
          A requirement of reasonableness is inherent in the concept of               
          necessary.  Boser v. Commissioner, 77 T.C. 1124, 1133 (1981).               
          Thus, expenses for travel, meals, and lodging must be both                  
          reasonable and necessary.  With these guidelines in mind we turn            
          to petitioner's expenditures for meals, lodging, transportation,            
          and other travel expenses.                                                  







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