Marc G. Bissonnette and Lillian I. Cone - Page 1

                                   127 T.C. No. 10                                    

                               UNITED STATES TAX COURT                                

               MARC G. BISSONNETTE AND LILLIAN I. CONE, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5988-05.             Filed October 23, 2006.                

                    P was a ferryboat captain for a company that                      
               carried travelers on sea voyages to destinations on                    
               Puget Sound, Washington.  The company’s home port was                  
               in Seattle, Washington.  P worked approximately 15- to                 
               17-hour days on turnaround runs completed within 24                    
               hours that each included a 6-hour layover at an away-                  
               from-home port during off-season voyages and a 1/2- to                 
               1-hour layover at an away from home port during peak-                  
               season voyages.  P paid for his meals and incidental                   
               expenses (M&IE) while traveling.                                       
                    P reported his M&IE incurred during these layovers                
               as miscellaneous itemized deductions under sec.                        
               162(a)(2), I.R.C., for 2001, 2002, and 2003.  The                      
               deduction amounts were ascertained from the Federal per                
               diem rates for M&IE as prescribed under Rev. Proc.                     
               2000-39, 2000-2 C.B. 340, and its successors.                          

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