- 6 -
Sailor required medical expenses $1,227
Sailor required supplies 655
Sailor uniforms/cleaning 692
Sailor union dues 914
======
3,488
OPINION
Section 162 permits taxpayers to deduct all ordinary and
necessary business expenses paid or incurred during the taxable
year and specifically includes traveling expenses (including
amounts expended for meals and lodging other than amounts that
are lavish or extravagant under the circumstances) while away
from home in the pursuit of a trade or business. Sec. 162(a)(2).
Section 274(d) generally disallows any deduction under section
162 for, among other things, “any traveling expense (including
meals and lodging while away from home)”, unless the taxpayer
complies with stringent substantiation requirements as to the
amount, time and place, and business purpose of the expense.
Sec. 274(d)(1). Section 274(d) authorizes the Secretary to
provide by regulations that some or all of these substantiation
requirements “shall not apply in the case of an expense which
does not exceed an amount prescribed pursuant to such
regulations.”
Under the applicable section 274 regulations, the
Commissioner is authorized to prescribe rules under which
optional methods of computing expenses, including per diem
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Last modified: March 27, 2008