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Petitioner argues that his home is "the base of my
operation" and that his only business office is in his home.
Petitioners claimed office-in-home expenses on Schedule C and
filed Form 8829, Expenses for Business Use of Your Home,
reporting expenses associated with the home office. No issue was
raised by respondent with respect to whether, and respondent did
not contest that, petitioner's business was run from his office
in his home.
Generally, expenses that a taxpayer incurs in commuting
between his home and place of business are personal and
nondeductible. Commissioner v. Flowers, 326 U.S. 465 (1946);
Heuer v. Commissioner, 32 T.C. 947, 951 (1959), affd. per curiam
283 F.2d 865 (5th Cir. 1960); secs. 1.162-2(e), 1.262-1(b)(5),
Income Tax Regs. Expenses incurred, however, in going between
two or more places of business may be deductible as ordinary and
necessary business expenses under section 162 if incurred for
business reasons. Steinhort v. Commissioner, 335 F.2d 496, 503-
504 (5th Cir. 1964), affg. T.C. Memo. 1962-233; Heuer v.
Commissioner, supra. A taxpayer may deduct the expenses of
traveling between two places of business, one of which is an
office in his home that is the taxpayer's principal place of
business for the trade or business conducted by the taxpayer at
those other work locations. Curphey v. Commissioner, 73 T.C.
766, 777-778 (1980).
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