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claimed a deduction for unreimbursed employee business expenses
in the amount of $5,904 for costs associated with the use of his
personal automobile for trips from his office to the Space Center
and to Loral. Petitioners computed this figure on Form 2106
attached to their return by multiplying Mr. Bradley's claimed
vehicle expenses for the year ($7,569) by a claimed business-use
percentage of 78 percent, for a product of $5,904 in vehicle
expenses attributable to business use. The business-use
percentage used by Mr. Bradley was calculated by dividing the
claimed business-use mileage of his vehicle for 1992 (9,974
miles) by the claimed total mileage for that year (12,816 miles).
Petitioners claimed an additional $189 in miscellaneous business
expenses for a total of $6,093 in unreimbursed employee business
expenses attributable to Mr. Bradley's employment.
In 1992, petitioner Emma J. Bradley (Mrs. Bradley) was
employed as a nurse by Gastroenterology Consultants (GC), a two-
physician medical practice with offices in Webster, Alvin,
Pasadena, and Houston, Texas. In carrying out her duties, Mrs.
Bradley was required to travel between the various offices. GC
had an established travel reimbursement policy under which
employees were reimbursed for business-related travel between its
2(...continued)
use of his personal automobile. Bradley v. Commissioner, T.C.
Memo. 1996-461. Our decision in the instant case does not, in
any event, depend upon Mr. Bradley's eligibility for
reimbursement.
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