- 12 - assignments during his normal shifts. Petitioner claimed that DHS told inspectors that they were not authorized for vehicle expenses reimbursement for overtime shifts because DHS was paying them overtime. Petitioner has not introduced any evidence to support his assertion that reimbursement was denied for any of his transportation in a personal automobile between duty posts (i.e., noncommuting transportation between business locations). Where an employee incurs expenses for which he is entitled to, but does not, seek reimbursement, he is not allowed to deduct those expenses. Walliser v. Commissioner, 72 T.C. 433, 437 n.4 (1979); Wollesen v. Commissioner, T.C. Memo. 1987-611, affd. without published opinion 875 F.2d 317 (4th Cir. 1989). Finally, even if petitioner claimed and DHS denied reimbursement for the noncommuting expenses, petitioner did not furnish any evidence to show how many of the miles driven were between places of business. The Court concludes that the evidence petitioner presented is insufficient to satisfy the strict substantiation requirements of section 274(d). Respondent’s determination as to the claimed vehicle expense deduction is sustained. Parking Fees and Tolls Petitioner claimed a deduction of $1,285 for unreimbursed parking fees and tolls. Petitioner did not provide any evidence to support these expenses, to demonstrate that they were forPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: March 27, 2008