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1. Petitioners’ Contentions
Petitioners contend that they used their cars almost
exclusively for business purposes, and that their use of the cars
to drive between their Fritchton residence and Barbara’s Gift
Shop was travel between two business offices because their cattle
business was located at their Fritchton residence. See secs.
274(d)(4), 280F(b)(3).
2. Commuting Expenses
The expenses of traveling between one’s home and place of
business are generally nondeductible, personal expenses. See
sec. 262; Fausner v. Commissioner, 413 U.S. 838, 839 (1973);
Commissioner v. Flowers, 326 U.S. 465, 473 (1946). A taxpayer
whose primary business activity is not located at his or her
residence may not deduct expenses of traveling between the
residence and the business merely because the taxpayer conducts a
secondary business at home. See Mazzotta v. Commissioner, 57
T.C. 427, 429 (1971), affd. 467 F.2d 943 (2d Cir. 1972); Andrews
v. Commissioner, T.C. Memo. 1978-135.
Petitioners conducted their primary business at 120 Main
Street. Even though petitioner fed the cattle when he was at the
Fritchton property and he and Mrs. Barmes worked some in the
farmhouse office, petitioners’ primary reason for traveling from
the gift shop to the Fritchton residence was personal.
Petitioners cite Heape v. Commissioner, T.C. Memo. 1992-660,
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