Michael E. Thibodeaux & Stephanie R. Thibodeaux, a.k.a. Stephanie R. Hearn - Page 5

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          business, as does the separate return previously filed by                   
          petitioner.  According to the Schedules C, the income and                   
          deductions listed on each has been computed in accordance with              
          the cash receipts and disbursements method of accounting.  On               
          each Schedule C a deduction of $1,522 for meals and entertainment           
          expenses is claimed.  On the Schedule C included with                       
          petitioner’s separate return a deduction of $4,034 for travel               
          expenses is claimed.  At the examination stage the parties                  
          proceeded as though the travel expense deduction was also claimed           
          on the joint return, even though it was not, and we do likewise.            
               The deduction for meals and entertainment expenses relates             
          to those items generally described above.  The deduction for                
          travel expenses relates to airfare, hotel, and local                        
          transportation expenses incurred for two trips to Jamaica, one in           
          January and one in December.  Petitioner described the trips as             
          “exploratory, investigative in nature” taken “because [he] was              
          attempting to get into * * * a real estate investment prospect”             
          that “did not reach fruition.”  Petitioner now concedes that                
          expenses totaling $2,430 incurred in connection with the December           
          trip are not deductible.                                                    
               In a notice of deficiency dated June 30, 2003, respondent:             
          (1) Disallowed the deduction for meals and entertainment                    
          expenses; (2) in effect, disallowed the deduction for travel                
          expenses for the Jamaican trips; and (3) imposed an addition to             






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