Richard Raymond Raush - Page 5

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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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