- 32 - Texas. See supra sec. II.D.4. During that period, Norman was in a travel status with respect to petitioner when he traveled away from Dallas in pursuit of petitioner’s business. The analyses show per diem payments to Norman for various dates (e.g., “11/3 – 11/5; 11/29 – 12/17) through April 18, 1994. We accept that Norman was traveling on behalf of petitioner, away from Dallas, on all dates through April 18, 1994, for which per diem payments are shown (all as reflected in the analyses and supporting documents).7 Per diem payments for such travel are deductible by petitioner. After April 18, 1994, Dallas no longer was Norman’s principal post of duty, see section III.D.4., and Norman has failed to prove that his principal post of duty was other than Washington, D.C., where he worked for 177 days during the 1994 tax year. See id. The analyses show per diem payments to Norman for every day from April 19, 1994, through the end of the 1994 tax year (the remainder of the year). Petitioner has failed to prove that Norman was in a travel status on every day during the remainder of the year. Nevertheless, the analyses and certain supporting documents allow us to determine that petitioner was outside of the Washington, D.C., area on petitioner’s business on 7 Petitioner’s payment of per diem to Norman and petitioner’s reimbursement of his miscellaneous travel expenses is evidenced by copies of canceled checks issued to Norman, which contain notations that they represent expense reimbursements. Also, respondent did not object to the amount of the per diem ($35 a day). Therefore, we do not consider the amount to be in issue.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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