- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007