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Under section 274(m)(2), no deduction is allowed "for travel
as a form of education." However, travel expenses to get to a
school, seminar, or conference where business-related education
is obtained can still be deductible. Sec. 1.162-5(d), Income Tax
Regs. Furthermore, commuting expenses from a taxpayer's home to
his or her place of study are nondeductible personal expenses.
Zimmerman v. Commissioner, 71 T.C. 367, 370 (1978), affd. without
published opinion 614 F.2d 1294 (2d Cir. 1979); Shelton v.
Commissioner, T.C. Memo. 1996-444; secs. 1.162-2(e), 1.262-
1(b)(5), Income Tax Regs.
Mrs. Whalley drove to class during the spring, summer,
winter, and fall. She kept a daily logbook to substantiate the
actual miles driven during each semester. However, at trial,
petitioner testified that Mrs. Whalley drove back and forth from
home to class, rather than from work to class. Mrs. Whalley did
not testify; consequently, we conclude that such expenses are
personal commuting expenses and therefore are not deductible
under section 262.
B. Travel Expenses While Away From Home
For 1991 and 1992, petitioners deducted $146 and $664,
respectively, for the cost of meals and lodging incurred by Mrs.
Whalley while away from home at business conferences.
Petitioners also deducted expenses for approximately 4,700 and
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