-14- respondent did not allow any deduction were incurred for ordinary and necessary business purposes in the course of petitioner’s carrying on a trade or business as either an independent contractor or an employee of IDA. Although section 162(a) is not mentioned in the notice, its provisions are implicit in respondent’s explanation that petitioner failed to establish that he incurred or paid the disallowed amounts for ordinary and necessary business purposes and that any amount qualifies as a business expense as specified under the provisions of the Internal Revenue Code. The notice alerted petitioner to respondent’s challenge to the bona fides of the disallowed amounts as travel expenses. The factual bases and rationale required to establish that the amounts petitioner paid for driving between Lancaster and Alexandria and for lodging and meals while working in Alexandria were ordinary and necessary business expenses incurred in his business of providing services to IDA as an independent contractor are identical to the factual bases and rationale necessary to establish that they were ordinary and necessary business expenses incurred in the business of providing services to IDA as an employee. In either case petitioner must show that (1) he was away from home when he incurred the expense, (2) the expense is reasonable and necessary, and (3) the expense was incurred in pursuit of a tradePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: March 27, 2008