In Marilyn Eileen Noz et vir (T.C. Memo. 2012-272) the Tax Court sided with the IRS in disallowing a number of the taxpayers' business deductions including those for flights from New York to Stockholm. The Court noted that on the basis of the frequency of travel, the personal relationship between the taxpayers, and the their failure to offer any evidence, beyond broad generalities, of how the trips advanced any stated business purpose, the Court found that the New York-Stockholm trips were motivated primarily by personal concerns and held they were not entitled to deduct the costs of their flights.
The Court also disallowed deductions for home internet use because the taxpayers provided no evidence regarding the percentage of internet use that was devoted to business purposes vs. the amount devoted to personal purposes. The Court declined to allow the accuracy-related penalty, finding that they at least partially complied with the record-keeping requirements and made a good-faith effort to act in accordance with the law.
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