- 2 -
Respondent determined deficiencies in petitioner's Federal
income taxes for the taxable years 1991 through 1993 as follows:
Year Deficiency
1991 $1,274
1992 1,120
1993 1,568
The issue for decision is whether petitioner may deduct
claimed employee business expenses for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. The stipulation and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition herein, petitioner resided at Cape Canaveral, Florida.
During the years in issue petitioner was a civilian mariner
assigned to the ship USNS Vanguard T-AG 194 with a port at Cape
Canaveral, Florida. The ship was part of the Military Sealift
Command (MSC). MSC is part of the U.S. Department of Defense
and, specifically, the U.S. Navy. Civilian employees operate,
maintain, and navigate the vessel to various locations as
designated by the Navy. The USNS Vanguard is operated by a
private company under contract with the U.S. Navy. Petitioner
worked as an engineer on the USNS Vanguard during the years in
issue.
During 1991 through 1993, petitioner apparently incurred
living, automobile, and travel expenses while the ship was in
port. On his Federal income tax returns for the years in issue,
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011