- 10 - cost in Saigans was not incurred as petitioner’s goods were moved between New York City, petitioner’s former residence, and Berkeley, petitioner’s new residence. Therefore, the storage cost incurred by petitioner in Saigans was not incurred in transit during petitioner’s move from New York City to Berkeley. Accordingly, the Saigans storage cost is not a deductible moving expense for purposes of section 217(a). However, petitioner’s AAAAA Storage expense was incurred during the 30-day period after the goods were moved from petitioner’s former residence, New York City, and before delivery at petitioner’s new residence, Berkeley. Accordingly, we hold that petitioner is entitled to an additional moving expense deduction under section 217(a) in the amount of $79 for the in- transit storage expense. E. Cost of Box Lost in Transit Petitioner has failed to substantiate the claimed loss of $2,350 with respect to the box lost in transit from New York City to Berkeley. Petitioner did not offer any evidence other than his testimony with respect to the cost or value of the contents of the box. There is no basis in the record for the Court to estimate such an expense under the Cohan rule. As such, we need not decide whether the value of the box that petitioner claims was lost by the moving company is a deductible moving expense for purposes of section 217. Accordingly, we hold that petitioner isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011