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On their 2003 return, petitioners claimed and respondent
disallowed the following itemized deductions under Job Expenses
and Most Other Miscellaneous Deductions:
Unreimbursed employee expenses $16,173
Tax preparation fees 595
Other expenses--Sailor Req’d Phone/Pager 1,282
Petitioners again attached a Sailor Travel Statement to their
2003 return to substantiate their claim to unreimbursed employee
expenses for that year. It included the Supplemental Tug/Barge
Sailor Travel Schedule reproduced below, the same authorities as
they had attached to their 2002 return, a 2003 port list for the
Yabucoa vessel, and a schedule listing ports where petitioner
purportedly was stationed on particular dates in 2003. The
Supplemental Tug/Barge Sailor Travel Schedule, with original
emphases, that petitioners attached to their 2003 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 2002-63’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 Foreign OCONUS Rates and Domestic CONUS Rates
for EACH CITY as follows:
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Last modified: March 27, 2008