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nondeductible personal expenses. See Commissioner v. Flowers,
supra at 472-474; Tucker v. Commissioner, 55 T.C. 783, 786
(1971).
The rationale behind this rule is that a taxpayer is free to
choose the location of his personal residence. See Anderson v.
Commissioner, 60 T.C. 834, 835 (1973). If we allowed the
taxpayer to deduct the commuting expenses, we would be permitting
the taxpayer to take a deduction for what is an inherently
personal expense. See id.; Alexander v. Commissioner, T.C. Memo.
1979-436.
In the instant case, we find that Mr. Knelman’s primary
motivation in traveling between Ohio and California was to
commute between the locations of his chosen residence and
business. Had petitioners remained in southern California, their
traveling expenses between work and home would also have been
nondeductible commuting expenses. The distance traveled, no
matter how far, does not change the character of the commuting
expense. See Commissioner v. Flowers, supra at 473.
Furthermore, petitioners have not presented any evidence
refuting respondent’s determination that the meals petitioners
deducted were nondeductible living expenses incurred as a result
of their decision to live outside the State where their
landscaping business is located. In the instant case, the
taxpayers, for personal reasons, wanted to reside in Ohio and
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