- 13 - 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).Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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