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other court, and this opinion shall not be treated as precedent
for any other case.
Manuel Ayala, Jr., and Carol A. Ayala (collectively,
petitioners) received a notice of deficiency in which respondent
determined: (1) Deficiencies in income taxes for 2002, 2003, and
2004 of $2,295, $4,050, and $4,459, respectively, and (2)
accuracy-related penalties under section 6662(a) for negligence
or intentional disregard of rules or regulations of $459, $810,
and $891.80, respectively. The basis for the deficiency
determination was the denial of deductions claimed by petitioners
for travel expenses under section 162(a)(2). We are asked to
decide whether petitioners may deduct those expenses. This
requires that we decide whether petitioners were “away from home”
when they incurred the expenses. If we sustain respondent’s
determination, we are also asked to decide whether petitioners
are liable for the accuracy-related penalties.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
Petitioners listed their mailing address on their petition
as Las Vegas, Nevada. Mr. Ayala testified at trial that
petitioners’ permanent mailing address is Rocklin, California.
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Last modified: November 10, 2007