- 7 -
68 Days x $87 Sat. Croix, Virgin Islands= 5,916.
40 Days x $75 Aguirre <San Juan>, Puerto Rico = 3,000.
25 Days x $75 Guayama <San Juan>, Puerto Rico = 1,875.
21 Days x $75 Arecibo <San Juan>, Puerto Rico = 1,575.
30 Days x $42 Kingston, New York = 1,260.
19 Days x $50 New York City <Manhattan>, NY= 950.
12 Days x $66 Puerto Plata, Dominican Rep.= 792
14 Days x $46 New Orleans, Louisiana = 644.
7 Days x $75 Mayaguez <San Juan>, Puerto Rico = 525.
6 Days x $75 San Juan, Puerto Rico = 450.
5 Days x $50 Brooklyn, New York = 250.
3 Days x $75 Yabucoa <San Juan>, Puerto Rico = 225.
2 Days x $38 Delaware City <Wilmington>, DE= 76.
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Total Sailor Travel Costs Allowed per OCONUS & CONUS Rates 17,538.
LESS EMPLOYER PROVIDED REIMBURSEMENTS <2,772>
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Sailor Travel Allowance in Excess of Reimbursements14,766.
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:
12 Days x $42 Tampa, Florida = 504.
Rental Cars & Other Travel Related Costs = 903.
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Total U.S. Tax Court & Other Sailor Travel Expenses Allowed 16,173.
=======
Petitioners concede that they are not entitled to any mileage or
rental car expense deductions claimed for 2003. Petitioners have
not provided any receipts, other documentation, or explanations
to substantiate the amounts or business purposes, if applicable,
of the expenses claimed for tax preparation fees and “Sailor
Req’d Phone/Pager” for 2003.
OPINION
Section 162 permits taxpayers to deduct all ordinary and
necessary business expenses paid or incurred during the taxable
year and specifically includes traveling expenses (including
amounts expended for meals and lodging other than amounts that
are lavish or extravagant under the circumstances) while away
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