Joon H. Chong and Youngcha Kim Chong - Page 12

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          deductible business travel.  Wisconsin Psychiatric Servs., Ltd.             
          v. Commissioner, 76 T.C. 839, 849 (1981); Curphey v.                        
          Commissioner, 73 T.C. 766, 777-778 (1980); Mazzotta v.                      
          Commissioner, 57 T.C. 427, 429 (1971), affd. per curiam 467 F.2d            
          943 (2d. Cir. 1972); Green v. Commissioner, T.C. Memo. 1989-599;            
          Kisicki v. Commissioner, T.C. Memo. 1987-245, affd. per curiam              
          without published opinion 871 F.2d 1088 (6th Cir. 1989); Adams v.           
          Commissioner, T.C. Memo. 1982-223, affd. without published                  
          opinion 732 F.2d 159 (7th Cir. 1984).  We have also allowed                 
          deductions for expenses incurred for transportation between an              
          individual's residence, which constituted a "regular place of               
          business", and the individual's "temporary places of business".             
          See Walker v. Commissioner, 101 T.C. 537 (1993) (applying Rev.              
          Rul. 90-23, 1990-1 C.B. 28).  However, because petitioner's house           
          was not his principal place of business, and because there is               
          nothing in the record that leads us to conclude that the hospital           
          was merely petitioner's temporary place of business, the above              
          cases provide no authority for allowing the car expense and                 
          depreciation deductions in dispute.  Accordingly, we sustain                
          respondent's determination with respect to the disallowed                   
          portions of petitioners' claimed car expense and depreciation               
          deductions.                                                                 
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               




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