- 29 - 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 toPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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