- 7 - never paid his fee. Thus, petitioner contends that he is entitled to a bad debt deduction for this amount. We disagree. On this record, there is no evidence whatsoever to support a finding that petitioner included in gross income the $2,626 in unpaid fee in either 1991, the year for which the deduction as a bad debt was claimed, or for a prior taxable year. Thus, because we find that petitioner did not include the $2,626 in income, petitioner is not entitled to a bad debt deduction under section 166. Gertz v. Commissioner, supra. Finally, we must decide whether petitioner is entitled to a deduction for rental payments for petitioner's house in Delhi in the amount of $4,800. Although petitioner claimed the rental payments on his Schedule C for Boozer, petitioner's management consultant business, petitioner contends that the rental payments were related to his mental health therapy business. Petitioner never explained why he failed to claim the rental payments on his Schedule C for Paradise, his mental health therapy business. Section 162 allows a deduction for ordinary and necessary traveling expenses (including amounts expended for meals and lodging) incurred by a taxpayer while away from home in the pursuit of a trade or business. This provision is an exception to the general rule under section 262 which states that personal, living, or family expenses are not deductible. Under section 162, a taxpayer must satisfy all of the following conditions:Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011