- 27 - 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) claimedPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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