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considerable distance from each other, generally, he is entitled
to deduct expenses incurred in traveling between such locations
and for meals and lodging incurred while away from his principal
place of business under section 162. Puckett v. Commissioner, 56
T.C. 1092, 1097 (1971). In determining which of two locations is
a taxpayer's principal place of business, the courts have
considered: the amount of time spent at each place; the
proportion of the taxpayer's income earned in each position; the
degree of activity engaged in by the taxpayer in each location;
where the taxpayer maintains his permanent residence; and whether
employment at one location is temporary. Puckett v.
Commissioner, supra at 1097; Sherman v. Commissioner, 16 T.C. 332
(1951); Hoeppner v. Commissioner, T.C. Memo. 1992-703.
Petitioner conceded the amount claimed on Schedule A of his
return for unreimbursed employee expenses. Respondent stated
that the concession was based on the fact that petitioner's
accountant had claimed identical travel expenses on Schedules A
and C of petitioner's return; thus the deductions were
duplicated. It is clear that petitioner's meals and
entertainment expenses were claimed both on Schedule A and
Schedule C in identical amounts. However, it is not clear from
the amounts claimed that the same is true for petitioner's travel
expenses consisting of amounts paid for airfare, lodging, and car
rentals. Petitioner could not explain how his accountant came up
with the total expenses as reported on his tax return. It
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