Raymond J. and Maria V. Zbylut - Page 18




                                        - 18 -                                        
               The credit card statements also show that petitioner was               
          present in Honolulu at least 14 days in June, during which period           
          he incurred expenses including some for lodging and meals.                  
          Petitioner asserts, and we believe, that he traveled to the                 
          Honolulu area union hall in June 2002 in search of a job, in                
          which endeavor he was successful.  Petitioner was employed by               
          Matson Navigation as a port relief engineer in Honolulu on three            
          different ships at various times totaling 9 days.  Matson                   
          Navigation provided petitioner with meals on the days he was                
          working aboard a vessel, and petitioner did not incur necessary             
          meal expenses during the 9 days when he was employed by Matson              
          Navigation.  Matson Navigation generally did not provide housing            
          for port relief engineers, and petitioner incurred lodging                  
          expenses for the 4 days that he was employed on two of Matson               
          Navigation’s ships in Honolulu.  However, petitioner did not                
          incur lodging expenses for the other 5 days he was employed by              
          Matson Navigation on the SS Manulani.  Petitioner also incurred             
          lodging and meal expenses for the remaining 5 days in Honolulu              
          during which he was seeking employment.                                     
               Petitioners claimed deductions for meals and incidental                
          expenses for 16 days in Honolulu on their 2002 return.                      
          Petitioners have shown that petitioner was present in Honolulu              
          and seeking employment or working for 14 days in June 2002.                 
          Petitioners are entitled to deductions at the applicable per diem           







Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next 

Last modified: March 27, 2008