- 15 - reimbursement program for mariner continuing education that covered tuition, hotel, and meal expenses for mariner continuing education courses, but not for travel expenses. On the Sailor Travel Statement attached to petitioners’ return for 2002, petitioners explained that the purpose of petitioner’s trip to Fort Lauderdale was to attend a continuing education program, the tuition for which was paid by petitioner’s union. At trial, petitioner testified that he attended a firefighting school with colleagues. Although given the opportunity, respondent did not question petitioner regarding the business purpose of the Fort Lauderdale trip or the business benefit that petitioner hoped to derive from his attendance at the firefighting school. Respondent’s only question on cross-examination regarding the Fort Lauderdale trip was whether petitioner kept a mileage log to substantiate the miles traveled on that trip. Petitioner answered in the negative. We hold that petitioner has adequately substantiated the business purpose of his travel expenses related to the Fort Lauderdale trip for firefighting school. Firefighting is related to petitioner’s employment as a merchant sailor and engineer. Payment for the course by petitioner’s professional union supports petitioners’ characterization of the related travel expenses as ordinary business expenses. We are not persuaded by respondent’s argument that, because petitioner did not seekPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: March 27, 2008