Charles A. Boyd and Darby A. Harvey, F.k.a. Darby A. Boyd, Petitioners<sup Id="fnr_fnote1"><a Href="fn_fnote1"…

Summary

The court sustained the disallowance of the taxpayers’ claimed deductions for driver per diem allowances, subject to a mathematical correction under the applicable rule. Because the allowances were calculated by miles driven, the governing revenue procedures treated them as paid solely for meals and incidental expenses, making the full allowance subject to the 50-percent deduction limitation. The court also held that driver testimony consisting of estimates and averages did not satisfy the strict substantiation requirements for travel expenses or justify an additional deduction for nonmeal expenses.