Joellen Miller Murata - Page 18

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                  Petitioner testified that she incurred miscellaneous                                 
            expenses related to her job search activities including newspaper                          
            costs.  Petitioner presented no documentation or detailed                                  
            testimony concerning these expenses.  Thus, she is not entitled                            
            to a deduction for these expenses.                                                         
                  Petitioner also contends that she is entitled to a per diem                          
            deduction for meals expenses for the 14 days during which she was                          
            in Los Angeles.  Rather than requiring that a taxpayer                                     
            substantiate the amount of the expenses incurred for meals, a per                          
            diem deduction may be allowed for meals expenses incurred away                             
            from home when a taxpayer satisfies all of the other requirements                          
            of sections 162(a)(2) and 274(d).  Sec. 274(d); sec. 1.274-5T(j),                          
            Temporary Income Tax Regs, 50 Fed. Reg. 46032 (Nov. 6, 1985);                              
            Rev. Proc. 90-60, 1990-2 C.B. 651, 653.  This amount will be                               
            deemed substantiated so long as the elements of time, place, and                           
            business purpose of the travel expenses are substantiated.  Rev.                           
            Proc. 90-60, 1990-2 C.B. 653.  The per diem meals amount includes                          
            incidental expenses such as laundry expenses.  Rev. Proc. 90-60,                           
            1990-2 C.B. 652.  Because petitioner has substantiated the                                 
            elements of time, place, and business purpose with respect to her                          
            second job search trip to Los Angeles, she is entitled to a per                            
            diem deduction for meals expenses for her 14-day trip.  The                                
            record does not reflect the allowable per diem amount for Los                              
            Angeles in a situation where housing is not included.  This may                            





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