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college required him to make the trip. He did not allocate his
travel expenses between business and personal expenses.
4. Portland, Oregon
On September 14, 2001, petitioner submitted to the college a
form P-2 regarding a trip to Portland. He attended the Community
College Humanities Association National Convention from October
24 through 28, 2001. During that convention, petitioner
presented the topic “How to Integrate Opera and Other Music into
the Humanities Curriculum”. He submitted receipts for lodging,
meals, and registration to the college and was reimbursed for a
total of $807.92 on November 19, 2001. Petitioner was not
reimbursed by the college for his airline ticket.
D. Petitioner’s Other Business Expenses
Petitioner also claimed a deduction for other business
expenses on his Form 2106 of $5,161.32. He did not seek
preapproval for these expenditures, nor did he request
reimbursement.
Respondent issued a statutory notice of deficiency to
petitioner in which he disallowed most of the employee expense
deductions petitioner claimed on Schedule A for lack of
substantiation as deductible section 162 expenses. Respondent
also determined petitioner is liable for an accuracy-related
penalty under section 6662(a).
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