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(1) Whether for the years in issue petitioners may deduct at
Federal per diem rates meal expenses that Jozsef Balla
(petitioner) did not pay for or incur;
(2) whether petitioners may deduct incidental expenses at
Federal per diem rates for 2003;
(3) whether petitioners may deduct mileage expenses for
travel to and from a firefighting school in April 2002;
(4) whether petitioners are entitled to deductions for other
job-related and miscellaneous expenses in 2002 and 2003.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Sarasota, Florida, at the time they filed
their petition.
Petitioner was employed by Hornbeck Offshore Operators
(Hornbeck) as a merchant sailor during the years in issue.
Hornbeck did not provide petitioner with a per diem cash
allowance for work-related meals or incidental expenses. When
petitioner was assigned to a vessel and on active status,
Hornbeck provided him with meals and lodging without charge.
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