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Respondent determined deficiencies of $4,580 and $5,259,
respectively, in petitioner’s 1995 and 1996 Federal income taxes,
and an addition to tax of $100 under section 6651(a)(1) for 1996.
The issues for decision are: (1) Whether for each year in issue
petitioner is entitled to deductions for meals and lodging
expenses; and (2) whether for 1996 petitioner is liable for an
addition to tax under section 6651(a)(1).
Background
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in San
Diego, California.
Petitioner is a special agent for the Naval Criminal
Investigative Service (NCIS). According to recruiting materials
published by NCIS,
During their careers, NCIS special agents can look
forward to a wide range of assignments, including some
overseas, in locations such as Great Britain, Italy,
and Japan. Tours of duty inside the continental United
States average from four to six years, depending upon
the needs of NCIS. Overseas tours vary from two to
three years generally, with opportunities to extend,
again depending on the needs of the service. Afloat
tours, and tours in a limited number of isolated
locations overseas, are generally limited to one year.
With the exception of afloat and isolated tours,
special agents are accompanied by their families.
Petitioner’s career as an NCIS special agent fits the above
description. He was hired in 1982 with a post of duty in Pearl
Harbor, Hawaii. His first 1-year afloat tour aboard an aircraft
carrier began in 1984. He was assigned to the Philippines from
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