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T.C. 824, 827 (1977). The purpose behind the deduction for
expenses paid or incurred while a taxpayer is away from home is
to ease the burden on the taxpayer who incurs additional and
duplicate living expenses. Rosenspan v. United States, 438 F.2d
905, 912 (2d Cir. 1971); Tucker v. Commissioner, 55 T.C. 783, 786
(1971).
Based on the record, we find that the arrangement in issue
meets the business connection requirement. The arrangement
provided a per diem allowance for petitioner's ordinary and
necessary traveling expenses incurred while away from his
Tennessee residence, which are allowed as a deduction under
section 162(a)(2). The amounts paid under the arrangement were
directly connected to petitioner's trade or business as Romer's
employee because he received the per diem allowance only for the
days on which he worked for Romer in Minneapolis.
Substantiation Requirement
Section 1.62-2(e)(1), Income Tax Regs., provides that an
arrangement satisfies the substantiation requirement if it
requires each business expense to be substantiated to the
employer within a reasonable period of time. In the case of
business expenses governed by section 274(d), section 1.62-
2(e)(2), Income Tax Regs., provides that an arrangement meets the
substantiation requirement if information sufficient to satisfy
the substantiation requirements of section 274(d) and the
regulations thereunder is submitted to the employer.
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