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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.
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