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deficiency, respondent aggregated these two deductions, and
reduced the total ($4,615) by $4,108 because petitioners did not
establish "that any amount more than $507 was for ordinary and
necessary business expense". Respondent did not explain in any
detail what portion of what deduction was being disallowed.
Although the record is less than clear on the point, respondent
claims, and petitioners do not appear to dispute, that the
disallowed portions of the deductions are attributable to
expenses incurred for travel between petitioner's house and the
hospital.
According to respondent, the disallowed portions of the
deductions constitute, or are attributable to, nondeductible
commuting expenses. Commuting expenses, which are transportation
expenses incurred between an individual's residence and regular
place of employment, are considered personal expenses, the
deduction of which is prohibited by section 262.5 Commissioner
v. Flowers, 326 U.S. 465, 470-474 (1946). Respondent's position
on this point obviously results in part from her determination
that petitioner's house was not his principal place of business.
We have held on numerous occasions that transportation
expenses incurred between an individual's residence and local job
sites may be deductible if his residence serves as his "principal
place of business" and the travel is in the nature of normal and
5Sec. 262 provides in relevant part, "no deduction shall be
allowed for personal, living, or family expenses."
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