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Respondent determined a deficiency in petitioners' Federal
income tax for 1993 in the amount of $2,509.
After a concession by petitioners,2 the issue remaining for
decision is whether petitioners are entitled to deductions for
ordinary and necessary expenses for travel while away from home
in the pursuit of a trade or business.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Downers Grove,
Illinois, on the date the petition was filed in this case. All
references to petitioner in the singular are to Steve
Pasharikoff.
In 1993, petitioner traveled to Miami, Florida, from his
home in Illinois to help his nephew repair property damage caused
by Hurricane Andrew. Petitioner shared a friend's one-bedroom
condominium, where he slept on a pullout couch.
Petitioner worked for Liberty Drywall, Inc. while he was in
Florida. His job entailed supervising various construction sites
and delivering building materials. Liberty Drywall, Inc.
provided petitioner with a truck for driving from his living
quarters to and between construction sites. As noted supra,
petitioner concedes that he received $8,930 in self-employment
income from Liberty Drywall, Inc. during 1993. Petitioner,
2 Petitioner husband concedes that he received and failed
to report $8,930 in self-employment income for 1993, as
determined by respondent in the statutory notice of deficiency.
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