10 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. ItPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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