Norman E. Duquette, Inc. - Page 27




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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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