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rely in support of their tax position, and documentation showing
the respective locations of petitioner and the President Wilson
on particular dates in 2002. The Supplemental Sailor Travel
Schedule, with original emphases, that petitioners attached to
their 2002 return is reproduced in part below:
Taxpayer is a Merchant Sailor assigned to work aboard a Cargo Ship
traveling between ports located around the entire Pacific Ocean
and therefore qualifies per attached Rev Proc 2001-47’s
“Transportation Industry Employees” and attached MARIN JOHNSON TAX
COURT DECISION & IRS Publication 463 (Chapter 1 Page 5) to compute
his DEEMED SUBSTANTIATED Out-of-Town Travel Costs by using
attached Pub 1542’s Foreign OCONUS Rates and Domestic CONUS Rates
for EACH CITY as follows:
27 Days x $119 Yokohama, Japan = 3,213.
23 Days x $76 Guam, Island of = 1,748.
15 Days x $82 Qingdao <Beijing>, China = 1,230.
10 Days x $87 Pusan, South Korea = 870.
14 Days x $50 San Pedro <L.A.>, California= 700.
6 Days x $113 Nagoya, Japan = 678.
7 Days x $84 Naha <Okinawa>, Japan = 588.
6 Days x $46 San Pedro <L.A.>, California= 276.
4 Days x $38 Oakland, California = 152.
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Total Sailor Travel Costs Allowed per OCONUS & CONUS Rates 9,455.
Taxpayer also took a Sailor Continuing Education Program. This
additional Rating is deductible since he already has other SAILOR
ratings and this course does NOT qualify him for a new occupation.
Note the Union paid the tuition in full. This is related
Educational Travel Expenses ONLY.
35 Days x $42 Easton <St. Michaels>, Maryland = 1,470.
Airfare & Other Education Related Costs = 1,272.
Less Union Education Reimbursement Per 1099 <2,712>
As a MERCHANT SAILOR, taxpayer was forced by his attached Union
Letter to personally show up at his Union Hall to look for his
next work assignment. He was NOT ALLOWED to simply phone his
Union Hall to see what new jobs were currently available. Per
attached IRS Publication 17, auto mileage and possibly other
travel-related costs back and forth to his Union Hall Looking
[sic] for work are FULLY DEDUCTIBLE as follows:
16 Days x $72 Honolulu <Oahu>, Hawaii = 1,152.
12 Days x $205 San Francisco, California= 2,460.
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Total U.S. Tax Court
& Other Sailor Travel Expenses Allowed 13,067.
In another statement attached to their 2002 return,
petitioners listed their other expenses as follows:
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Last modified: March 27, 2008