- 4 - documents entitled “Sailor Travel Statement” to substantiate their claim to unreimbursed employee expenses. The Sailor Travel Statement includes the “Supplemental Tug/Barge Sailor Travel Schedule” reproduced below, authorities upon which petitioners rely in support of their tax position, a 2002 port list for the Yabucoa vessel, and a schedule listing ports where petitioner purportedly was stationed on particular dates in 2002. The Supplemental Tug/Barge Sailor Travel Schedule, with original emphases, that petitioners attached to their 2002 return is reproduced in part below: Taxpayer is a Merchant Sailor assigned to work aboard a Tug Boat traveling between ports located on the Atlantic Ocean and therefore qualifies per attached Rev Proc 2001-47’s “Transportation Industry Employees” and attached MARIN JOHNSON TAX COURT DECISION & IRS Publication 463 (Chapter 1 Page 5) to compute his DEEMED SUBSTANTIATED Out-of-Town Travel Costs by using attached Pub 1542’s Standard Foreign OCONUS Rates for EACH CITY as follows: 80 Days x $75 Guayama <San Juan>, Puerto Rico = 6,000. 39 Days x $75 Arecibo <San Juan>, Puerto Rico = 2,925. 44 Days x $57 Guayaquil, Ecuador = 2,508. 25 Days x $76 St. Croix, Virgin Islands= 1,900. 33 Days x $57 Mayaguez <Other>, Puerto Rico= 1,881. 18 Days x $75 San Juan, Puerto Rico = 1,350. 4 Days x $75 Aguirre <San Juan>, Puerto Rico = 300. 5 Days x $57 Yabaccoa <Other>, Puerto Rico= 285. -------- Total Sailor Travel Costs Allowed per OCONUS Rates17,149. LESS EMPLOYER PROVIDED REIMBURSEMENTS <2,852> -------- Sailor Travel Allowance in Excess of Reimbursements 14,297. As a MERCHANT SAILOR, taxpayer was required by his employer to travel to various locations to meet his ships. Per IRS Rev Rul 99-7 and attached Marin Johnson Tax Court Decision, his auto mileage and possibly other travel-related costs are FULLY DEDUCTIBLE as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008