Randolph John Beale - Page 14




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                  it is the delivery point or facility, not the                                        
                  taxpayer's residence, where the most important                                       
                  functions of the business are undertaken.  [Id. at                                   
                  176.]                                                                                
                  In this case, petitioner provided no evidence as to how many                         
            hours he worked at home compared to hours he visited clients'                              
            business sites.  Although he presumably kept records, made                                 
            telephone calls, and perhaps did some drafting at his home                                 
            office, this evidence is insufficient to allow us to determine                             
            whether petitioner performed most or the most important of his                             
            consulting services in his attached garage or at his clients'                              
            business sites.  Accordingly, in the absence of proving that his                           
            residence was his "principal place of business", petitioner is                             
            not entitled to deductions for the home office expenses.                                   
                  Automobile Expenses                                                                  
                  For each year in issue, petitioner claims expenses for                               
            mileage associated with driving his automobile from his residence                          
            to various client locations while pursuing his consulting                                  
            business.  Respondent disallowed all of petitioner's claimed                               
            expenses.                                                                                  
                  It is well settled that, as a general rule, the expenses of                          
            traveling between one's home and his place of business or                                  
            employment constitute commuting expenses which are nondeductible,                          
            personal expenses.  See sec. 262; Fausner v. Commissioner, 413                             
            U.S. 838 (1973); Commissioner v. Flowers, 326 U.S. 465 (1946);                             







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