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b. Travel Expenses Relating to Petitioner’s Nashville-
Based Employment With Flagship Airlines
Background
On March 4, 1991, Flagship Airlines (a division of American
Airlines, Inc.), in Nashville, Tennessee, employed petitioner as
a pilot.18 Shortly thereafter, petitioner moved to Tennessee.
From March through December 1991, and thereafter, petitioner
resided in Antioch, Tennessee, located near Nashville.19 After
moving to Tennessee, petitioner leased his house in Minneapolis
to an unidentified tenant.
After moving to Tennessee, petitioner divided his time
between Nashville and Minneapolis, where he continued to attend
to his accounting business and his other aviation activities.
Petitioner alleges that he would typically spend “two, three, and
sometimes four consecutive days in Nashville” and then return to
Minneapolis.20
17(...continued)
90-60 at sec. 7.01, 1989-2 C.B. at 799; Rev. Proc. 89-67 at sec.
7.01, 1990-2 C.B. at 656.
18 On his 1991 Federal income tax return, petitioner
reported wages from Flagship Airlines in the amount of $11,226.
19 For purposes of simplicity and clarity, and because
Antioch is located close to Nashville, references hereinafter to
Nashville will include references to Antioch.
20 The record does not specifically indicate where
petitioner lodged when he was in Minneapolis, after moving to
Tennessee.
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