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deduction. See Boyd v. Commissioner, 122 T.C. at 320; Watson v.
Commissioner, T.C. Memo. 1988-29.
Petitioners have shown that they at one time possessed
adequate documentation to establish the required elements for
deducting Dr. Rinker’s business travel expenditures. Petitioners
have also shown that their failure to produce those records
stemmed from circumstances beyond their control; namely, that Mr.
Hertz lost the records. Petitioners have also provided a
reasonable reconstruction of some of Dr. Rinker’s expenditures
for business travel away from home in 1999. We therefore allow
petitioners’ deductions for which petitioners have provided
adequate reconstructions of Dr. Rinker’s deductible business
travel expenditures.
Deductible traveling expenses include travel fares, meals
and lodging, and expenses incident to travel. Sec. 1.162-2(a),
Income Tax Regs. From the record before us, petitioners have
reconstructed the following deductible travel expenses:
Nature of
Date Expenditure Destination Business Purpose Amount
2/2 Fuel Las Vegas American Academy $19.46
of Anti-Aging
Medicine conference
4/26 Hotel Fresno University pharmacy 77.28
conference
4/27 Car rental Fresno University pharmacy 22.20
conference
4/27 Hotel Fresno University pharmacy 219.02
conference
6/11 Hotel San Francisco Psychiatry 285.36
conference
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