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entertainment, (4) the business relationship to the taxpayer of
each expenditure or use. Sec. 274(d)(4).
A. Expenses Relating to Mr. Claborn’s Employment With
ResourceTek LLC
Mr. Claborn has submitted hotel receipts and a mileage log
in support of claimed deductions relating to his temporary
employment with ResourceTek LLC.5 However, even setting aside
the substantiation requirements, the evidence of record reflects
that Mr. Claborn was reimbursed for the expenses that he incurred
during his brief employment with ResourceTek LLC for which he
claims a deduction. In that regard, in response to a request
from ResourceTek LLC for a canceled check reflecting that he had
received a per diem allowance, Mr. Claborn was provided a
document reflecting that he was paid an untaxed per diem
allowance that amounted to $400 weekly.6 Although it is unclear
exactly how much of a deduction petitioners think they are
entitled to for expenses relating to Mr. Claborn’s temporary
employment with ResourceTek LLC, petitioners have failed to
demonstrate expenses exceeding Mr. Claborn’s $400 weekly per diem
allowance. Accordingly, petitioners are denied a deduction for
5 Respondent does not contest the temporary nature of Mr.
Claborn’s employment with either ResourceTek LLC or RWE NUKEM
Corporation.
6 In addition, Mr. Claborn’s employment agreement with
ResourceTek LLC provided for the possibility of a per diem
allowance.
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Last modified: November 10, 2007