Shawn M. and Debra E. Swagler - Page 11

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          Commissioner, 56 T.C. 936, 943 (1971), affd. without published              
          opinion 456 F.2d 1335 (2d Cir. 1972) (same).                                
               Mr. Swagler claimed a deduction for vehicle expenses but he            
          failed to keep any mileage records and could have been reimbursed           
          by his employer.  Mrs. Swagler also claimed a deduction for                 
          vehicle expenses, but she did not provide any documentation to              
          substantiate them and her testimony failed to address them.                 
               Respondent allowed petitioners a deduction for vehicle                 
          expenses in the amount of $975.  Because petitioners have                   
          failed to prove that the determination is erroneous, the Court              
          sustains respondent on this issue.                                          
               b.   Travel and Lodging/Meals and Entertainment Expenses               
               The deduction of travel expenses away from home, including             
          meals and lodging, under section 162(a)(2), is also conditioned             
          on such expenses' being substantiated by adequate records or by             
          other sufficient evidence corroborating the claimed expenses                
          pursuant to section 274(d).  Sec. 1.274-5T(a)(1), Temporary                 
          Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).                        
               Although Mr. Swagler testified that he attended various fire           
          and rescue training sessions throughout Illinois, he failed to              
          provide any documentation with respect to his claimed travel and            
          lodging expenses.  Respondent's disallowance of petitioners'                
          claimed travel and lodging expenses is sustained.                           








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