Richard Lewis Field - Page 8

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               Generally, no deduction is allowed for personal, living, or            
          family expenses.  See sec. 262.  A taxpayer must show that any              
          claimed business expenses were incurred primarily for business              
          rather than personal reasons.  See Rule 142(a).  To show that an            
          expense was not personal, the taxpayer must show that the expense           
          was incurred primarily to benefit his business, and there must              
          have been a proximate relationship between the claimed expense              
          and the business.  See Walliser v. Commissioner, 72 T.C. 433, 437           
          (1979).                                                                     
               1.   Traveling Expenses                                                
               On Schedule C, petitioner claimed a deduction of $2,073.50             
          for traveling expenses.  Petitioner made a total of 54 trips in             
          year 2000 for the purpose of “business development” in connection           
          with Field Investment Management.  He produced a copy of the                
          pages from his day planner which set forth the name of the                  
          “client”, the mileage traveled, the date, and the alleged                   
          business purpose of each trip.  On the 54 trips taken, petitioner           
          met with a total of four different persons.  Petitioner’s day               
          planner shows that he met with a Ms. Hurd, a person whom he                 
          identified as an employee of Comerica Bank, on 38 of the trips.             
          He testified that he met with her to give investment advice.  He            
          did not provide any information regarding the other three                   
          persons.                                                                    







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