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Area Number Reported
of Of M&IE Incidental
Travel Days Rate Expenses
Juneau, Alaska 103 $80 $8,240
Gustavus, Alaska 68 62 4,216
Sitka, Alaska 56 58 3,248
Ketchikan, Alaska 19 70 1,330
Petersburg, Alaska 14 62 868
Wrangell, Alaska 4 70 280
Yakutat, Alaska 4 58 232
Total 268 18,414
In total, petitioner reported $18,714 of miscellaneous
itemized deductions for 1996, and he claimed on his 1996 return
that he was entitled to deduct $16,956 of that amount after
taking into account the 2-percent floor of section 67.
Respondent determined that petitioner could not deduct any of the
$18,414.
OPINION
We must decide whether petitioner may deduct the cost of the
incidental travel items which he purchased during the subject
year while working away from his home. Petitioner argues he may.
Petitioner asserts that he incurred the costs while working away
from home on business. Petitioner asserts that the applicable
revenue procedures dispense with the need to substantiate the
amount of those costs in order to deduct them. Respondent argues
that petitioner may not deduct those costs. Respondent asserts
primarily that petitioner had no tax home. Respondent asserts
secondly that petitioner did not prove that he actually incurred
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Last modified: May 25, 2011