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matter of legislative grace, and petitioner bears the burden of
proving his entitlement to such deductions. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). We find that petitioners
have submitted sufficient proof that during 1992 petitioner
incurred rent expenses in the amount of $1,952.62, which amount
is $179.27 more than the amount allowed by respondent.
C. Automobile Expense Deduction
At trial, petitioners claimed that they were entitled to an
automobile expense deduction in the amount of $587.81 for 1992 in
connection with petitioner's educational seminars business. This
amount represents expenses incurred for repairs, towing service,
and license registration for petitioner's pickup truck.
Automobile expenses are deductible pursuant to section 162 only
with respect to that portion of the automobile's use attributable
to business. The portion attributable to personal use is
nondeductible. Petitioner has the burden of proving what portion
of his automobile expenses was for business purposes and what
portion was for personal purposes. Cobb v. Commissioner, 77 T.C.
1096, 1101 (1981).
According to petitioner, he drove his truck from his house
to Sierra. He would then walk from Sierra to the classroom,
which was located less than one block away. Simply put,
petitioner used his pickup truck to commute from his residence to
his place of employment. The expenses of commuting are not
deductible. Commissioner v. Flowers, 326 U.S. 465, 470-474
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