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with the rental of the Bethesda apartment by the action of the
board, authorizing the rental of a corporate apartment, and the
use of the Bethesda apartment by Norman on the 177 days during
the 1994 tax year that he worked in Washington. Therefore, we
find that petitioner incurred, and has adequately substantiated,
traveling expenses on account of the travel of Norman to
Washington, in an amount equal to that portion of the Bethesda
apartment expenses incurred on or before April 18, 1994.
5. Conclusion
We shall sustain respondent’s determination of a deficiency
to the extent based on a disallowance of a deduction for the
Bethesda apartment expenses only to the extent of such expenses
incurred after April 18, 1994.
III. Travel Expenses
On the 1994 tax return, under the heading “Other
Deductions”, petitioner deducted $45,937.83 for “Travel”.
Respondent disallowed all "other deductions" on the grounds “that
it has not been established that any amount claimed constitutes
an ordinary and necessary business expense, was expended or was
expended for the purpose designated.”
We may dispose of this item without much discussion. The
parties have stipulated to a “meal analysis” and a “travel
analysis” prepared by petitioner, which analyses (the analyses)
contain details of the travel expenses (travel expenses) claimed
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