Pavel Dobra and Ana Dobra - Page 17

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          is his (or her) "principal place of employment", rather than his            
          “residence”.  See Mitchell v. Commissioner, 74 T.C. 578 (1980);             
          Kroll v. Commissioner, 49 T.C. 557 (1968).                                  
               We believe that the authorities under section 162 do not               
          undermine our conclusion that “home” requires a residential                 
          connection for purposes of section 131.  It is a fundamental                
          policy of Federal income tax law that a taxpayer should not be              
          entitled to a deduction for “personal” expenses, such as the                
          ordinary expenses of everyday living.  This policy is evidenced             
          by section 262(a), which states that "Except as otherwise                   
          expressly provided * * * no deduction shall be allowed for                  
          personal, living, or family expenses.”  The interpretation of               
          “home” to mean "principal place of business" for purposes of                
          section 162(a)(2) has been based upon this policy.  See Kroll v.            
          Commissioner, supra at 562.                                                 
               By contrast, we do not ascertain any legislative intent                
          underlying section 131--or any policy of the statute as a whole--           
          that either permits or requires us to depart from the general               
          rule that our interpretation be governed by the plain meaning of            
          the statutory language.14  To the extent we are able to determine           

               14 See United States v. Ron Pair Enter., Inc., 489 U.S. 235,           
          242 (1989) (quoting Griffin v. Oceanic Contractors, Inc., 458               
          U.S. 564, 571 (1982)):  “The plain meaning of legislation should            
          be conclusive, except in the `rare cases [in which] the literal             
          application of a statute will produce a result demonstrably at              
          odds with the intentions of its drafters’”; see also United                 
          States v. American Trucking Associations, Inc., 310 U.S. 534,               
          543-544 (1940).                                                             



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