- 37 - purpose of the travel expenses in accordance with those regulations.” Rev. Proc. 90-15, 1990-1 C.B. at 476. Petitioners have provided no substantiation for the time, place, and business purpose for any of the claimed per diem expenses. We hold, therefore, that petitioners are not entitled to any deduction for per diem away-from-home expenses for 1993 or 1994. Issue 7. Section 179 Deduction Petitioners owned a 1989 Chevrolet that was used exclusively for personal transportation. In October of 1994, petitioners traded the Chevrolet, along with cash, for a Ford van. Petitioner explained in his testimony that he purchased the Ford van to use as sleeping quarters when he visited his Kentucky farm “rather than pay $75-$100 a night for a motel”. He also used it to “haul a tiller, plows, farm implements, this sort of thing” to the farm in 1994. Petitioner testified that he drove the van a total of 2,234 miles of which 1,866 miles were accumulated from the trip to Virginia to pick up the “farm stuff” take it to Kentucky, and return to Illinois. In their amended petition, petitioners claimed that respondent had improperly failed to consider their claim for $12,000 in farm equipment expenses “not properly claimed on petitioners’ returns as filed.” During the trial (before respondent had located petitioners’Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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