Reza and Connie M. Rezazadeh - Page 18

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          Her research was used by petitioner at the Omaha, Nebraska,                 
          conference.                                                                 
               On their 1991 Federal income tax return, petitioners claimed           
          unreimbursed employee business expenses of $1,525.32 for the                
          travel expenses incurred by Mrs. Rezazadeh for her research trip            
          to Bogota.  More specifically, the expenses claimed included the            
          standard mileage rate for automobile travel from petitioners'               
          home in Platteville to the airport in Chicago, Illinois, and back           
          to Platteville, the round-trip airfare from Chicago to Bogota,              
          miscellaneous meals and lodgings in Chicago, parking at the                 
          Chicago airport, meals in Bogota, and the Bogota Airport                    
          departure tax.  Expenses for lodging in Bogota were not claimed             
          because Mrs. Rezazadeh stayed with her relatives.  In the notice            
          of deficiency, respondent disallowed the claimed employee                   
          business expenses, determining that the primary purpose of the              
          trip was for pleasure, not business.  At trial, respondent                  
          acknowledged that Mrs. Rezazadeh did spend some time doing                  
          research while she was in Bogota.                                           
               Section 162(a) allows a deduction for all ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business.  Such deductions include                 
          traveling expenses incurred while away from home in the pursuit             
          of a trade or business, including amounts expended for meals and            
          lodging.  Sec. 162(a)(2).  If travel expenses are incurred for              





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