Thomas J. Mitchell and Janice M. Mitchell - Page 5

                                        - 5 -                                         

          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                            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011