Robert and Cheryl McKeown - Page 7

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               The parties resolved many of the disputed expenses before              
          trial.  We are asked to determine whether petitioners are                   
          entitled to deduct the remaining expenses.  We begin by                     
          considering whether Mr. McKeown was away from home when he                  
          incurred expenses for his vehicle, transportation, and meals in             
          Detroit, Newark, and New York.                                              
          Travel Expenses While Away From Home                                        
               We begin by briefly outlining the rules for deducting travel           
          expenses.  A taxpayer may deduct reasonable and necessary travel            
          expenses such as those for vehicles, meals, and lodging incurred            
          while away from home in the pursuit of a trade or business.                 
          Secs. 162(a)(2), 262(a).  A taxpayer must show that he or she was           
          away from home when he or she incurred the expense, that the                
          expense is reasonable and necessary, and that the expense was               
          incurred in pursuit of a trade or business.  Commissioner v.                
          Flowers, 326 U.S. 465, 470 (1946).  The determination of whether            
          the taxpayer has satisfied these requirements is a question of              
          fact.  Id.                                                                  
               The purpose of the deduction for expenses incurred away from           
          home is to alleviate the burden on the taxpayer whose business              
          needs require him or her to maintain two homes and therefore                
          incur duplicate living expenses.  Kroll v. Commissioner, 49 T.C.            
          557, 562 (1968).  The duplicate costs are not deductible where              

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