Ann Jorgensen - Page 6

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          petitioner is entitled to $103 of the disallowed deductions for             
          1995 and $320 of the disallowed deductions for 1996.  The                   
          remaining disallowed deductions are for the expenditures                    
          associated with petitioner's participation in the Legendary                 
          Greece and Southeast Asia courses.  Respondent maintains that               
          these expenses were incurred for travel as a form of education              
          and that such expenses are nondeductible under section 274(m)(2).           
          In the alternative, respondent argues that even if the expenses             
          are for education other than that which resulted from the travel            
          itself, the expenses are nevertheless not deductible under                  
          section 162 because they are not ordinary and necessary business            
               Section 162(a) permits a deduction for all ordinary and                
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.  Such expenses generally include           
          expenditures for travel, including amounts expended on meals and            
          lodging, while away from home in the pursuit of a trade or                  
          business.  See sec. 162(a)(2).                                              
               In contrast, no deductions are allowed for personal, living,           
          or family expenses unless otherwise expressly provided by the               
          Internal Revenue Code.  See sec. 262(a).  Expenditures made by a            
          taxpayer in obtaining or furthering education are considered                
          personal expenses and are not deductible unless they qualify                

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