Steve J. Work - Page 8

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          13213 apply to expenses incurred after December 31, 1993.  OBRA             
          sec. 13213(e), 107 Stat. 475.  Before its amendment by OBRA,                
          former subparagraphs (D) and (E) of section 217(b)(1) allowed               
          deductions for expenses of meals and lodging while occupying                
          temporary quarters and qualified residence sale or purchase                 
          expenses.                                                                   
               Petitioner incurred his moving expenses after December 31,             
          1993.  Accordingly, any expenses for temporary housing, for the             
          sale of his former residence, and for the purchase of a new                 
          residence are not deductible pursuant to section 217.                       
          Furthermore, section 217 does not allow a deduction for                     
          relocation allowances.                                                      
               Section 1.217-2(b)(3), Income Tax Regs., provides:                     
               Expenses of moving household goods and personal effects                
               include expenses of transporting such goods and effects                
               from the taxpayer’s former residence to his new                        
               residence, and expenses of packing, crating, and in-                   
               transit storage and insurance for such goods and                       
               effects. * * *  Expenses of storing and insuring                       
               household goods and personal effects constitute in-                    
               transit expenses if incurred within any consecutive 30-                
               day period after the day such goods and effects are                    
               moved from the taxpayer’s former residence and prior to                
               delivery at the taxpayer’s new residence. * * *                        
               Expenses of moving household goods and personal effects                
               do not include, for example, storage charges (other                    
               than in-transit) * * * .                                               
               On May 22, 1998, petitioner sold his house in Northglenn,              
          Colorado.  On May 27, 1998 petitioner purchased a house in Fort             
          Collins, Colorado.  Petitioner, however, presented no evidence              
          regarding whether the items in storage were moved from his former           





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