T.C. Memo. 1997-105
UNITED STATES TAX COURT
RAYMOND STRONG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27340-90. Filed March 3, 1997.
During 1987, petitioner (P) was a business manager at
two automobile dealerships. P claimed various employee
business expense deductions, primarily for business meals.
1. Held: P is not entitled to deductions for business
meals expenses because he has not satisfied the requirements
of sec. 274, I.R.C. 1986.
2. Held, further, deductions are not allowable for P’s
otherwise deductible other employee business expenses
because they do not in the aggregate exceed the 2-percent
floor on miscellaneous itemized deductions. Sec. 67, I.R.C.
1986.
3. Held, further, P is liable for additions to tax
under secs. 6653(a)(1) and 6661(a), I.R.C. 1986.
Stuart E. Abrams, for petitioner.
Mark A. Ericson, Nancy Chassman Rothbaum, and Rosemarie D.
Camacho, for respondent.
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