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Feistman v. Commissioner, 63 T.C. 129 (1974); Sullivan v.
Commissioner, 1 B.T.A. 93 (1924).
This Court has previously held that a taxpayer's cost of
transportation between his residence and local job sites may be
deductible if his residence serves as his "principal place of
business" and the travel is in the nature of normal and
deductible business travel. See Wisconsin Psychiatric Servs.,
Ltd. 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).
In Walker v. Commissioner, 101 T.C. 537 (1993), where the
taxpayer's residence was considered his "regular" place of
business rather than his "principal" place of business, the
taxpayer was allowed to deduct transportation expenses incurred
between his residence and local, temporary job sites. However,
as we stated in Strohmaier v. Commissioner, 113 T.C. 106, 114
(1999):
the conclusion in Walker was based on a concession of
the issue by the Commissioner based on Rev. Rul 90-23,
1990-1 C.B. 28. This revenue ruling has subsequently
been amended to reflect existing case law as
articulated above. See Rev. Rul. 94-47, 1994-2 C.B.
18.
Accordingly, to be entitled to deduct automobile expenses,
petitioner must prove that his residence was used as his
"principal place of business". Since petitioner was unable to do
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