- 29 -
The travel expenses set forth in the analyses are supported
by other stipulated exhibits, including canceled checks, copies
of credit card statements, and a daily diary kept by Norman,
which corroborates the list of miscellaneous expenses for
parking, tolls, taxis, gasoline, tips, etc., set forth in one of
the analyses. We find that those exhibits, plus the parties’
stipulation and Norman’s testimony (not disputed by respondent)
that virtually all of the travel expenses associated with visits
to business clients that are listed on the analyses were
reimbursed by such clients, constitute adequate substantiation of
the amounts, time and place, and business purpose of such
expenses as required by section 274(d) and the regulations.
Travel expenses incurred in connection with the trips to Florida,
which we have found to be personal trips, and all travel expenses
incurred by Norman in the Washington, D.C., area after April 18,
1994 (not shown to be other than commuting expenses), are not
included within that finding on the ground that such expenses do
not constitute expenses associated with business travel while
away from home as required by section 162(a)(2).
Based upon the foregoing criteria, we find that petitioner
incurred deductible travel expenses for the 1994 tax year in the
amount of $30,958.
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