Michel L. Dixon - Page 8




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          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 expense             





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