- 2 - deductible. See sec. 280A(c)(1)(A), I.R.C.; Commissioner v. Soliman, 506 U.S. 168, 175-177 (1993). 2. Held, further, the car and truck expenses incurred by P between his residence and the places where he conducted religious services and the car and truck expenses between his residence and the first and last place of insurance customer contact each day are not deductible as transportation expenses but are nondeductible commuting expenses. See secs. 262, 162(a), I.R.C.; Wisconsin Psychiatric Servs. v. Commissioner, 76 T.C. 839, 849 (1981); Curphey v. Commissioner, 73 T.C. 766, 777-778 (1980); Heuer v. Commissioner, 32 T.C. 947, 953 (1959), affd. per curiam 283 F.2d 865 (5th Cir. 1960); Walker v. Commissioner, 101 T.C. 537 (1993), distinguished. 3. Held, further, expenses incurred for meals, in the absence of overnight lodging, are not deductible as travel expenses away from home under sec. 162(a)(2), I.R.C., where the meal expenses incurred are occasioned by the taxpayer's rests to accommodate a medical condition. See United States v. Correll, 389 U.S. 299 (1967); Barry v. Commissioner, 54 T.C. 1210 (1970), affd. per curiam 435 F.2d 1290 (1st Cir. 1970). Walter R. Strohmaier, pro se. Robert W. Dillard, for respondent. OPINION PARR, Judge: This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182. The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below. 1Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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