- 14 -
subsequently been amended to reflect existing case law, as
articulated above. See Rev. Rul. 94-47, 1994-2 C.B. 18. Since
petitioner's residence was not his "principal place of business",
it follows that the expenses relating to the disallowed mileage
for each year constitutes commuting expenses that are not
deductible. Respondent is sustained on this issue.
The third issue is petitioner's entitlement to deductions
for travel expenses for 1993 and 1994 in connection with his
insurance and ministerial activities. Petitioner claimed $4,106
and $4,977, respectively, for 1993 and 1994, for travel expenses.
In the notice of deficiency, respondent allowed petitioner a
deduction of $50 for each year based on one out-of-town overnight
trip by petitioner each year. Respondent determined that the
disallowed amounts, $4,056 and $4,927, respectively, for 1993 and
1994, did not represent travel away from home, and, therefore,
such amounts were not deductible. Petitioner agreed that, as to
the amounts at issue, he was not away from home overnight and did
not obtain lodging in connection with those expenses. The
disallowed amounts represented costs of meals petitioner incurred
in connection with his two business activities.
Petitioner contends that he incurred the meal expenses
because he suffered with a medical condition, apnea, which
required that he take rest periods during the day. As a result,
his work day, in each of the instances he sustained such
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