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out of personal preference and not because of any business
necessity. Commissioner v. Flowers, 326 U.S. 465 (1946).
We conclude that petitioner's "home" for purposes of section
162(a)(2) was in Calexico. Accordingly, we hold that he is not
entitled to his claimed deduction for traveling expenses paid in
connection with his employment in Calexico because he was not
"away from home" when such expenses were paid. Respondent's
determination on this issue is sustained.
The second issue for decision is whether petitioner received
and failed to report interest income in the amount of $116.
On his 1993 return, petitioner reported that he received
interest income from Bank of America in the amount of $795. In
the statutory notice of deficiency, respondent determined that
petitioner failed to report an additional $116 of interest income
as reported to respondent by Bank of America on a Form 1099-INT.
Section 61(a) includes in gross income all income from
whatever source derived including, but not limited to, interest.
Sec. 61(a)(4). In his petition to the Court, petitioner
contended that "as far as I know my interest income was declared
in full". At trial, respondent's counsel stated that she had
copies of respondent's information return program documents that
show the unreported amount determined in the statutory notice of
deficiency, but that she did not "intend to introduce them into
evidence". In addition, a copy of the Form 1099-INT from Bank of
America was not made part of the record in this case. In the
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