Lorenzo Battle - Page 14

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                    c.   Travel Expenses                                              
               Petitioner claimed deductions of $1,540 for travel expenses.           
          Petitioner indicated on the spreadsheet, under the category of              
          miscellaneous, that he paid travel expenses of $897.71 in                   
          connection with Zomans Productions.  Petitioner also indicated              
          that he paid toll charges of $161.05 with his EZ Pass and                   
          attributed half of that amount to Zomans Productions.  Petitioner           
          claims that these travel expenses were for trips to Miami,                  
          Florida, and Ocean City, Maryland, for the purpose of shooting              
          stock footage for his movie production business.                            
               Petitioner testified that his Miami trip had a “dual role”.            
          The second purpose of the trip was to attend a student                      
          conference.  The student conference was unrelated to petitioner’s           
          business, but he claims to have shot some footage at the                    
          conference for use in a possible project.  Petitioner provided              
          receipts for the Miami trip but not for the Ocean City trip.  The           
          receipts for Miami show that some of the travel expenses were               
          incurred by another individual.  No information, however, was               
          provided regarding that individual.                                         
               The Court has reviewed petitioner’s evidence and finds that            
          it is insufficient to satisfy the strict substantiation                     
          requirements of section 274(d).  See sec. 1.274-5T(b)(2),                   
          Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).              







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