- 30 -
curiam 283 F.2d 865 (5th Cir. 1960); secs. 1.162-2(e), 1.262-
1(b)(5), Income Tax Regs. Expenses incurred, however, in going
between two or more places of business may be deductible as
ordinary and necessary business expenses under section 162 if
incurred for business reasons. See Steinhort v. Commissioner, 335
F.2d 496, 503-504 (5th Cir. 1964), affg. T.C. Memo. 1962-233;
Heuer v. Commissioner, supra at 953.
Where a taxpayer attempts to deduct the expenses of traveling
between two places of business, one of which is an office in his
home, that office must be the taxpayer’s principal place of
business for the trade or business conducted by the taxpayer at
those other work locations. See Strohmaier v. Commissioner, 113
T.C. 106 (1999); Curphey v. Commissioner, 73 T.C. 766, 777-778
(1980). On his Schedules C for 1993 and 1994, line 30, “Expenses
for business use of your home”, petitioner listed zero.
Petitioner offered no evidence and made no argument that his
“principal place of business” was at his home. Commissioner v.
Soliman, 506 U.S. 168, 175-177 (1993).
2. Farm Use
At the very bottom of the second page of his “Reconstruction
of Miles Driven” for 1993, there is a notation that petitioner
drove a total of 3,715 miles to and from “Farm” on April 22, June
13, July 28, and October 11, 1993, for “CROPS”. In view of other
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