William J. McNeill - Page 3




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          house was for the telephone.  He paid no rent there and did not             
          contribute to mortgage payments.                                            
               In April 1998, petitioner agreed to buy a friend’s mobile              
          home in Bonne Terre, Missouri (the mobile home), making payments            
          of about $1,000 per year before receiving title to the mobile               
          home in 2001.  In 1998 and 1999, petitioner paid no utilities or            
          maintenance expenses with respect to the mobile home.  In 1998,             
          petitioner would stop at the mobile home only for a few hours               
          while reloading his truck.  In 1999, petitioner spent about 20              
          days at the mobile home.                                                    
               For each year at issue, petitioner filed a Form 1040, U.S.             
          Individual Income Tax Return.  On Schedule C, Profit or Loss From           
          Business (Schedule C), attached to his 1998 return, petitioner              
          deducted $8,006 for travel expenses and $6,480 for meals                    
          expenses.  On Schedule C attached to his 1999 return, petitioner            
          deducted $5,799 for travel expenses and $5,760 for meals                    
          expenses.  In the notice of deficiency, respondent disallowed all           
          these claimed deductions.                                                   
                                     Discussion                                       
               The cost of traveling, including food and lodging, is                  
          generally considered a nondeductible personal expenditure.  See             
          Deamer v. Commissioner, 752 F.2d 337, 338 (8th Cir. 1985), affg.            
          T.C. Memo. 1984-63.  A deduction is allowed, however, for                   
          ordinary and necessary business expenses, including “traveling              






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