Jozsef and Zsuzsanna Balla - Page 17




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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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