Russell B. Ritchie - Page 8

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          situations requiring transportation expenses for which Stores               
          would not have reimbursed him.  He alleged that his                         
          transportation expense deduction was related to the unscheduled             
          “emergency” trips.                                                          
               Petitioner’s evidence on the issue consisted of Stores’                
          check stubs showing reimbursements to him of $1,550, presumably             
          for scheduled trips, and a computer-generated monthly log titled            
          “Mileage - Tax Year 2002”, purporting to show cumulative monthly            
          mileage to “county locations” in 2002.  It is interesting to note           
          that the same three counties, Orange, “LA”, and San Diego, as               
          well as “miscellaneous mileage” are listed every month.  The                
          total mileage traveled each month is also fairly consistent.                
          According to petitioner’s evidence, his “emergency” unscheduled             
          transportation expenses were a startling 623 percent of his                 
          reimbursed expenses for scheduled trips.                                    
               Further complicating matters for petitioner, the Court is              
          unable to determine from his evidence which of his trips were               
          reimbursed and which were not because his evidence does not meet            
          the standard of section 274(d).  Respondent’s determination on              
          this issue is sustained.                                                    
               Other Expenses                                                         
               Petitioner claimed $1,245 of “other” business expenses.  The           
          Court presumes that the Verizon Wireless cell phone bills and               
          miscellaneous receipts offered by petitioner were submitted as              






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