Travis and Jayne Sanderson - Page 5

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          unreimbursed employee expenses for the 1994 tax year on Form 2106           
          in the following amounts:                                                   
               Expenses                                Amount                         
               Vehicle expenses                        $4,048                         
               Meal and entertainment expenses         6,422                          
               Travel and lodging expenses             5,680                          
               Total                                   16,150                         

               Respondent determined that petitioners were not entitled to            
          deduct unreimbursed employee expenses in the amount of $15,123 as           
          traveling expenses incurred while away from home because                    
          petitioner's employment with Motorola was for an indefinite term,           
          and, therefore, respondent disallowed the amount.  Petitioners              
          contend that petitioner's home was in Arlington, Texas, and that            
          petitioner incurred deductible unreimbursed employee expenses               
          while petitioner was temporarily working for Motorola in Seguin,            
          Texas.                                                                      
          Discussion                                                                  
               1.  Unreimbursed Employee Expense Deductions                           
               Deductions are a matter of legislative grace.  New Colonial            
          Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).  Taxpayers bear             
          the burden of proving that they are entitled to the deductions              
          they claim.  Welch v. Helvering, 290 U.S. 111, 115 (1933).                  
               Section 162(a) allows a taxpayer to deduct all ordinary and            
          necessary business expenses paid or incurred during the taxable             
          year in carrying on any trade or business.  No deduction is                 
          allowed for personal, living, or family expenses.  Sec. 262.                




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