Nicholas M. Romer - Page 39




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          City, Missouri, where he resided for personal reasons to which              
          his employment with the Kansas Air Force Reserve was incidental).           
          In any event, the record provides no basis for determining what             
          portion, if any, of petitioner’s rental expenses might be                   
          properly attributable to his presence in Nashville for the                  
          performance of business duties, as opposed to his presence there            
          for personal reasons.                                                       
               We conclude and hold that the Nashville apartment rental and           
          utilities expenses are not deductible travel expenses under                 
          section 162(a)(2).                                                          
                  (iii)  Nashville Meals and Incidental Expenses                      
               As previously discussed, the evidence in the record does not           
          adequately substantiate the time, place, or business purpose of             
          petitioner’s travel.  Petitioner seems to suggest that with                 
          respect to the days he resided in Nashville, the time, place, and           
          business purpose of his travel are substantiated because of his             
          employment there with Flagship Airlines.  We disagree,                      
          particularly as to the element of business purpose.   As                    
          previously discussed, for the majority of taxable year 1991,                
          petitioner’s sole personal residence was in Nashville.                      
          Petitioner failed to establish the requisite business purpose for           
          his stays in Nashville.                                                     
              To the extent petitioner’s claim is predicated on travel               
          expenses that might have been incurred in connection with his               
          employment with Flagship Airlines while he was away from his                





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