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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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