Norman E. Duquette, Inc. - Page 29




                                       - 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.                                                          










Page:  Previous  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  Next

Last modified: May 25, 2011