- 2 - may deduct the traveling expenses at issue. We hold they may.1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the subject years. Rule references are to the Tax Court Rules of Practice and Procedure. References to petitioner in the singular are to Thomas J. Mitchell. FINDINGS OF FACT Some of the facts have been stipulated. The stipulation of facts and the exhibits submitted therewith are incorporated herein by this reference. Petitioners resided in Lockport, Illinois, when their petition was filed. They were husband and wife during the relevant years, and they filed joint Federal income tax returns for those years. Petitioner was born in December 1933, and he has worked and lived in the Chicago, Illinois, area for most of his life. After living outside of the Chicago area for a brief period of time before 1990, he moved in 1990 back to the Chicago area, settling in a suburb called Orland Park, Illinois. While living in Orland Park, he began to consult as an independent contractor for a printing company in New York, New York. He worked out of his home, using a room that he had set up as his business office. 1 Our holding on this issue also means that petitioners are not liable for the accuracy-related penalties in dispute, all of which relate solely to the traveling expenses.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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