Jozsef and Zsuzsanna Balla - Page 5




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                    8 Days x  $205 Boston, Massachusetts    =  1,640.                 
                    5 Days x  $142 Fort Lauderdale, Florida =    710.                 
                    Rental Cars & Other Travel Related Costs=  1,175.                 
               Taxpayer also took a Sailor Continuing Education Program.  This        
               additional Rating is deductible since he already has other SAILOR      
               ratings and this course does NOT qualify him for a new occupation.     
               Note the Union paid the tuition in full.  This is related              
               Educational Travel Expenses ONLY.                                      
                    Total Mileage: 563 miles x $.365        =    205.                 
                    6 Days x  $42 Fort Lauderdale, Florida  =    252.                 
                    5 Days x  $46 New York City <Manhattan>, NY=    230.                 
                                                            -------                   
               Total Tax Court & IRS Allowed Sailor Travel  18,509.                   
               & Auto Mileage                               =======                   
                                                                                     
               Petitioners concede that they are not entitled to deductions           
          for any of the mileage or rental car expense deductions claimed             
          for 2002 except the $205 claimed for the round trip mileage from            
          petitioner’s home in Sarasota to Fort Lauderdale, Florida, where            
          petitioner attended the firefighting school in April 2002.                  
          Respondent concedes that petitioners are entitled to a                      
          miscellaneous itemized incidental expenses deduction for 2002               
          equal to the per diem rates then applicable.  Respondent                    
          performed those calculations according to methods established by            
          relevant revenue procedures.                                                
               In a statement attached to their 2002 return, petitioners              
          listed their “other expenses” as follows:                                   
                    Sailor Req’d Medicals              $155                           
                    Sailor Req’d Phone/Pager           2,345                          
                    Sailor Req’d Supplies              643                            
          They provided no receipts, other documentation, or explanations             
          to substantiate the amounts or business purposes of the expenses            
          claimed.                                                                    






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