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Following concessions, the traveling expenses at issue are as
follows:
1994 1995
Apartment $14,950 $15,705
Travel 14,050 12,501
Meals and entertainment 4,805 3,360
Utilities 1,015 1,243
All of the disputed expenses for travel and for meals and
entertainment relate to petitioner's travel between Orland Park
and California. The cost of the apartment was less than the
amount that petitioner would have had to pay had he stayed in a
hotel room during his time in California.
Throughout all of the relevant years, petitioner was
registered to vote in Illinois, he registered his car in
Illinois, and he maintained his only checking account in
Illinois. Petitioner's only connection to California was that he
performed services there.
During the relevant years, ACN did not restrict petitioner
from providing additional consulting services to other companies,
and it did not give him an office at its Century City location.
Petitioner offered his consulting services to other prospective
clients during those years.
OPINION
We must decide whether petitioners may deduct the traveling
expenses in dispute. Petitioners contend that they may because
petitioner was away from his tax home in Orland Park while
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