- 9 - 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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