Theodore W. Keller - Page 6

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                  $   202  Vehicle expenses                                                               
            48  Parking fees                                                                              
            7,610  Sabbatical expenses:                                                                   
            $  791  Air, bus, etc.                                                                        
            593  Shipping, passports                                                                      
            254  Local transportation                                                                     
            4,486  Lodging                                                                                
            1,318  Utilities                                                                              
            168  Utilities                                                                                
                  2,874  Meals (80 percent of actual amount)                                              
            $10,734  Total (prior to deduction of 2 percent of adjusted                                   
            gross income under sec. 67(a))                                                                

                  In the notice of deficiency, respondent disallowed the                                  
            $10,734 on the ground that "no deduction is allowed for costs of                              
            travel that constitutes a form of education".  At trial,                                      
            respondent agreed that petitioner had incurred the amounts                                    
            claimed but contended that such expenses were not allowable                                   
            deductions under section 274(m)(2).                                                           
                  Deductions are strictly a matter of legislative grace, and                              
            the taxpayer bears the burden of proving entitlement to any                                   
            deductions claimed.  Rule 142(a); New Colonial Ice Co. v.                                     
            Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S.                             
            111 (1933).                                                                                   
                  Section 162(a) permits a deduction for all ordinary and                                 
            necessary expenses paid or incurred during the taxable year in                                
            carrying on a trade or business.  Such expenses generally include                             
            expenditures for travel while away from home in the pursuit of a                              
            trade or business.  The word "travel" includes meals and lodging.                             
            Sec. 162(a)(2).                                                                               




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