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temporarily working in Century City and Riverside. Respondent
contends that they may not because petitioner's tax home was
Century City. Petitioners bear the burden of proving that
petitioner's tax home was not in Century City. See rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933); Daly v.
Commissioner, 72 T.C. 190, 197 (1979), affd. 662 F.2d 253 (4th
Cir. 1981).
A taxpayer ordinarily may not deduct a personal expense.
See sec. 262. A taxpayer may deduct an expense, however, to the
extent that it is: (1) A reasonable traveling expense (e.g.,
lodging, transportation, fares, and food), (2) incurred while
away from home, and (3) an ordinary and necessary expense
incurred in pursuit of a trade or business. See sec. 162(a)(2);
Commissioner v. Flowers, 326 U.S. 465, 470 (1946). The purpose
behind this deduction is to alleviate the burden falling upon a
taxpayer whose business requires that he or she incur duplicate
living expenses. See Tucker v. Commissioner, 55 T.C. 783, 786
(1971); Kroll v. Commissioner, 49 T.C. 557, 562 (1968). Whether
the taxpayer satisfies the three conditions necessary for this
deduction is purely a question of fact. See Commissioner v.
Flowers, supra at 470; see also Wills v. Commissioner, 411 F.2d
537, 540 (9th Cir. 1969), affg. 48 T.C. 308 (1967).
The parties dispute only the situs of petitioner's tax home;
thus, we limit our inquiry to that question. The U.S. Supreme
Court has held that a taxpayer may not deduct the expenses of
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