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on a trip that requires sleep or rest. See United States v.
Correll, 389 U.S. 299 (1967). This rule “requires a stop of
sufficient duration that it would normally be related to a
significant increase in expenses.” Barry v. Commissioner, 435
F.2d 1290, 1291 (1st Cir.), affg. 54 T.C. 1210 (1970).
To be deductible as an expense incurred while “away from
home”, a travel expense must be reasonable and necessary, and
incurred in pursuit of business. Sec. 162(a)(2); see
Commissioner v. Flowers, supra at 470. To be deductible under
section 162(a)(2), travel expenses must meet the heightened
substantiation requirements of section 274(d). See sec.
274(d)(1).
a. Travel Expenses Relating to Petitioner’s Minneapolis-
Based Aviation Activities
Petitioner claims travel expenses relating to his
Minneapolis-based aviation activities. These travel expenses
include but are not limited to meals, lodging, rental cars, tips,
shoe shines, and laundry. Petitioner kept no contemporaneous
log, diary, journal, or calendar of these expenses. Instead,
petitioner presented voluminous documentary evidence consisting
of photocopies of his flight logbooks, receipts, canceled checks,
credit card statements, and a check register. Many of these
expenditures were allegedly made with cash, and petitioner has
offered no documentary evidence to substantiate that they were
actually made.
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