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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