- 8 - Proc. 93-21, 1993-1 C.B. 529, in support of his argument. That revenue procedure relaxes some of the strict substantiation requirements of section 274(d) under certain circumstances; however, none apply to petitioner. Petitioner did not receive a per diem allowance from any payor, and he did not incur the meals expense as a self-employed individual. The revenue procedure does not apply, and petitioner cannot rely upon it to support any portion of the deduction claimed on his 1993 return or his claim for an additional deduction. Petitioner has failed to satisfy the requirements of section 274(d) with respect to any traveling expense that he might have incurred in seeking employment as a school principal during 1993. Therefore, he is not entitled to a deduction for any such expense, and respondent's determination in this regard is sustained. Petitioner also now claims that he is entitled to an additional deduction for unreimbursed travel expenses incurred as an employee of the Department of Defense. Petitioner made a claim to his employer for reimbursement, but his claim was denied because it was submitted late. Assuming that the claim was otherwise valid, had petitioner submitted the reimbursement claim timely, the claim would have been paid. If a taxpayer is eligible to be reimbursed for an expense from his or her employer but fails to make a proper claim for reimbursement, the expensePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011