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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 attendance
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