- 7 - amount of reimbursement petitioner received from the State of Mississippi on their Federal joint income tax returns for 1990, 1991, and 1992. Furthermore, petitioners deducted travel, lodging, and meal expenses that were not reimbursed by the State of Mississippi for petitioner's attendance at the court in Jackson. Notice of Deficiency In the notice of deficiency, respondent determined that petitioners underreported their income for each of the years in issue by the amount of travel, lodging, and meal expense reimbursements petitioner received from the State of Mississippi. Respondent further disallowed petitioners' deduction for unreimbursed travel, lodging, and meal expenses for the years in issue. At trial, respondent conceded that the transportation expenses incurred by petitioner relating to his travel between jobs in Jackson, Mississippi, as a Justice of the Mississippi Supreme Court and Oxford, Mississippi, as an adjunct professor of law at the University of Mississippi are deductible for those days in which petitioner traveled from Jackson to Oxford for the purpose of teaching classes. See Rev. Rul. 61-67, 1961-1 C.B. 25, modified by Rev. Rul. 76-453, 1976-2 C.B. 86. OPINION Our task herein is to decide whether the travel, lodging, and meal expense reimbursements paid to petitioner for his attendancePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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