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amounts of these expenses or the job-related business purpose for
those expenses. Petitioner’s employer, Hornbeck, did not require
its sailors to carry cell phones or pagers and provided its
employees with required safety equipment and supplies during the
years in issue. Thus, even if the amounts had been
substantiated, these expenses were not ordinary or necessary
business expenses and were properly disallowed by respondent as
deductions.
In reaching our decision, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
irrelevant, moot, or without merit.
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008