Steven J. and Terry L. Namyst - Page 9

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          Cir. 2003).  Respondent admits that petitioner was an employee of           
          IMC during all of the years in issue.                                       
               In the notice of deficiency and on brief, respondent allowed           
          deductions under section 162 for the expenses petitioner paid in            
          connection with the performance of services as an employee of               
          IMC.  A deduction under section 162(a) requires that the reported           
          expenses be “directly connected with or pertaining to” the                  
          taxpayer’s trade or business.  Sec. 1.162-1(a), Income Tax Regs.            
          Petitioner kept track of the expenses he made carefully, even               
          deducting sales tax from his expense reports when his own                   
          personal purchases were on receipts with purchases he made for              
          IMC.  Petitioner was dedicated to IMC’s business, and the work he           
          was doing to develop IMC’s products.  We believe that the                   
          expenses he made and listed on the expense reports were directly            
          connected to IMC’s business of developing its products.                     
          Therefore, we conclude that the business connection requirement             
          was met here.                                                               
               B.   Substantiation Requirement                                        
               An arrangement meets the substantiation requirement if it              
          requires that each business expense be substantiated to the payor           
          within a reasonable period of time.  Sec. 1.62-2(e)(1), Income              
          Tax Regs.  A reasonable period of time depends on the facts and             
          circumstances of each arrangement.  Sec. 1.62-2(g)(1), Income Tax           
          Regs.  For travel, entertainment, and other expenses governed by            






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