- 24 -
In support of respondent’s position that petitioner is not
entitled to deduct any of the traveling expenses that petitioner
claims with respect to the Tacoma property, respondent contends
that petitioner failed to prove (1) that those claimed expenses
are ordinary and necessary expenses paid or incurred for the
production or collection of income and/or for the management,
conservation, or maintenance of property held for the production
of income under section 212 and (2) that petitioner complied with
the substantiation requirements of section 274(d).
An individual is allowed a deduction for all the ordinary
and necessary expenses paid or incurred for the production or
collection of income and for the management, conservation, or
maintenance of property held for the production of income. Sec.
212(1) and (2). Section 274(d) operates to disallow any
22(...continued)
Type of Expense Amount
Airplane flights $1,443.00
Car rentals 478.63
Meals 2,476.22
Parking 263.00
Hotels 559.69
Gasoline 21.00
Total $5,241.54
In addition to the foregoing stipulated expenses that
petitioner paid, petitioner contends that he is entitled to
deduct with respect to the Tacoma property a car rental expense
of $365.21 and a taxi expense of $50, both of which he claims he
paid.
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011