- 18 -
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
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: May 25, 2011