Nicholas M. Romer - Page 29




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               Accordingly, having failed to prove that his home was his              
          principal place of business, petitioner is not entitled to                  
          deductions for home office expenses.                                        
               12.  Automobile Mileage Expenses                                       
               Petitioner seeks to deduct Minneapolis-area vehicle mileage            
          expenses of $5,992, $5,866, and $1,248 for taxable years 1989,              
          1990, and 1991, respectively.  He alleges that these expenses               
          arose from driving his automobiles from either his residence or             
          from Romer & Co. to, among other places, airports and various               
          retailers to make purchases for his aviation activities.                    
               A taxpayer’s costs of commuting to and from his place of               
          business are nondeductible, personal expenses.  See Fausner v.              
          Commissioner, 413 U.S. 838 (1973); Commissioner v. Flowers, 326             
          U.S. 465 (1946); Feistman v. Commissioner, 63 T.C. 129, 134                 
          (1974); secs. 1.162-2(e) and 1.262-1(b)(5), Income Tax Regs.  A             
          taxpayer’s costs 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.  Strohmaier v.                       
          Commissioner, 113 T.C. at 113-114; Wis. Psychiatric Servs., Ltd.            
          v. Commissioner, 76 T.C. 839, 849 (1981); Curphey v.                        
          Commissioner, 73 T.C. 766, 777-778 (1980).                                  
               As we held above, petitioner failed to prove that his                  
          residence was the “principal place of business” for his aviation            
          activities.  Consequently, mileage expenses for trips either to             





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