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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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Last modified: May 25, 2011