- 2 - (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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008