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(1) Whether for the years in issue petitioners may deduct at
Federal per diem rates meal expenses that Raymond J. Zbylut
(petitioner) did not pay or incur;
(2) whether petitioners are entitled to deductions for
expenses related to petitioner’s travel to union halls in 2002;
and
(3) whether petitioners are entitled to deductions claimed
for other job-related expenses in 2002.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Nebraska at the time they filed their
petition.
Petitioner was employed as a merchant sailor at various
times in 2002 by American Ship Management, L.L.C. (American
Ship), and by Matson Navigation Co. (Matson Navigation). During
that year, American Ship provided meals and lodging without cost
to petitioner whenever he was on active status and assigned to a
vessel for that company. Petitioner worked for American Ship
aboard a container vessel called the President Wilson for
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