Jiri Cerny v. Commissioner of Internal Revenue Service
Opinion
Opinion
2 F.3d 1156 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jiri CERNY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70123. United States Court of Appeals, Ninth Circuit. Submitted June 25, 1993. * Decided July 7, 1993. Before CANBY, FERNANDEZ and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Jiri Cerny appeals pro se the tax court's decision finding that he was not entitled to deduct meals, lodging, and transportation expenses for tax year 1986 pursuant to 26 U.S.C. Sec. 162 (a)(2). We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 (a), and we affirm. 3 Section 162(a) of the Internal Revenue Code allows taxpayers to deduct "traveling expenses (including amounts expended for meals and lodging other than amounts which are lavish or extravagant under the circumstances) while away from home in the pursuit of a trade or business." 26 U.S.C. Sec. 162 (a)(2). The tax court, relying on our decision in James v. United States,…