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Petitioner did not receive a per diem cash allowance or
reimbursement for lodging, meals, or incidental expenses from
American Ship or Matson Navigation in 2002. He was not a
permanent or indefinite employee of either employer or of any
other company during 2002. He served only in temporary positions
on various vessels that year and then returned to his home in
Nebraska for vacation and during periods of unemployment.
In addition to wages from American Ship and Matson
Navigation, petitioner received unemployment compensation in 2002
from the New York State Department of Labor-Unemployment
Insurance.
Petitioners filed their Form 1040, U.S. Individual Income
Tax Return, for 2002 over 9 months late on January 28, 2004.
Petitioners did not request an extension of time to file their
2002 return.
Under Job Expenses and Most Other Miscellaneous Deductions
on their Schedule A, Itemized Deductions, for 2002, petitioners
claimed the following deductions:
Unreimbursed employee expenses $13,067
Other expenses 3,488
Petitioners attached an extensive compilation of documents
entitled “Sailor Travel Statement” to substantiate their claim
for unreimbursed employee expenses. The Sailor Travel Statement
included, among other things, the “Supplemental Sailor Travel
Schedule” reproduced below, authorities upon which petitioners
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