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resume helping it in California on an as needed basis.
Petitioner accepted. In the middle of 1995, ACN changed its
print shop to one in Stillwater, Oklahoma, and petitioner
traveled to Stillwater to advise ACN on its printing process.
Petitioner was in California for 113 days during 1995, and he
worked for ACN on each of those days. He worked in Riverside on
18 days and in Century City on 95 days. He worked for ACN on 90
days while in Orland Park and on 21 days while in Stillwater.
Ms. Sweetland died in 1996. Three days later, ACN told
petitioner that his services in Century City were no longer
needed. ACN told petitioner that it wanted him to continue
advising it on its printing process.
During 1994 and 1995, petitioner traveled between Orland
Park and California about 14 times (all between January to May or
July to November), and he rented a small one-bedroom apartment in
Century City in which he placed minimal furnishings. Petitioner
deducted his travel and apartment expenses on his 1994 and 1995
tax returns. Respondent disallowed the following expenses
(referred hereinafter as traveling expenses):
1994 1995
Apartment $14,950 $15,705
Travel 14,050 15,251
Meals and entertainment 4,805 5,260
Utilities 1,015 1,243
Insurance 717 1,110
Total 35,537 38,569
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Last modified: May 25, 2011