Steve and Lura Pasharikoff - Page 3

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          however, claims that he is entitled to offset such income with              
          deductions for living expenses paid while he was working in                 
          Florida.                                                                    
               Deductions are strictly a matter of legislative grace, and             
          petitioners bear the burden of proving their entitlement to any             
          deductions claimed.  Rule 142(a); INDOPCO, Inc. v. Commissioner,            
          503 U.S. 79, 84 (1992); Hradesky v. Commissioner, 65 T.C. 87                
          (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976)  In                   
          general, deductions for personal living expenses are disallowed             
          under section 262.                                                          
               Section 162(a)(2) allows deductions for traveling expenses             
          if the expenses are:  (1) ordinary and necessary; (2) incurred              
          while away from home; and (3) incurred in pursuit of a trade or             
          business.  Bochner v. Commissioner, 67 T.C. 824, 827 (1977).  The           
          purpose behind the deduction for expenses paid while a taxpayer             
          is away from home is to ease the burden on the taxpayer who                 
          incurs additional and duplicate living expenses.  Rosenspan v.              
          United States, 438 F.2d 905, 912 (2d Cir. 1971); Tucker v.                  
          Commissioner, 55 T.C. 783, 786 (1971).                                      
               Petitioner testified that he paid $500 per month as rent for           
          his living quarters, in addition to other living expenses such as           
          food, laundry, and gasoline for his truck.  Petitioner also                 
          testified that he paid $1,500 to repair the truck provided to him           
          by Liberty Drywall Inc.  Petitioner, however, failed to produce             
          any receipts, documentary evidence, or witnesses at trial in                
          support of his alleged expenses.  It is well established that, in           



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