- 4 - petitioner received $4,639 in 1995. These wages were reported by the city on a Form W-2, Wage and Tax Statement. Petitioner failed to file income tax returns for taxable years 1990, 1992, 1993, 1994, and 1995. On July 15, 1999, respondent mailed petitioner a notice of deficiency for those years. The deficiency was based on income from the band for the taxable years in question and the city of Madison for 1995. On March 2, 2001, petitioner submitted to respondent’s counsel a band engagement log, returns, and completed Forms 1040, U.S. Individual Income Tax Return, reflecting income received from the band and the city of Madison. The returns also reflected business expenses on a Schedule C, Profit or Loss From Business, of $123 per day for the following numbers of days in Chicago: 102 days in 1990, 97 days in 1992, 98 days in 1993, 101 days in 1994, and 75 days in 1995. Petitioner did not claim business expense deductions for his meals when the band played in cities other than Chicago. OPINION Section 162 allows deductions for all ordinary and necessary expenses incurred in carrying on a trade or business. Sec. 162(a). These expenses include traveling expenses (i.e., meals and lodging) while away from home. Sec. 162(a)(2). However, section 162 does not allow deductions for personal, living, orPage: Previous 1 2 3 4 5 6 7 8 Next
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