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Petitioner contends that Minneapolis remained his tax home
in 1991. For 1991, petitioner seeks to deduct as travel expenses
$3,552 of “duplicate living expenses” that he allegedly incurred
while residing and working in Nashville, away from his tax home
of Minneapolis. These asserted deductions fall into three
general categories: (1) Rent and utilities for an apartment in
Nashville; (2) meals and incidental expenses relating to his
Nashville employment; and (3) expenditures for the purchase and
repair of two automobiles in Nashville.21 Petitioner argues
alternatively that if Nashville were his tax home in 1991, he is
entitled to deduct $7,580 for duplicate living costs he incurred
in Minneapolis. Respondent contends that petitioner’s tax home
for taxable year 1991 was Nashville and that petitioner is not
entitled to deduct living costs incurred in Minneapolis.
Discussion
(i) Petitioner’s Tax Home
In the context of section 162(a)(2), “home” generally means
the vicinity of the taxpayer’s principal place of employment,
rather than the site of the taxpayer’s personal residence. See
Mitchell v. Commissioner, 74 T.C. 578, 581 (1980). When a
taxpayer has businesses or employment in two places distant from
one another, his tax home for purposes of section 162(a)(2) is
21 To the extent that petitioner has asserted deductions for
his costs of traveling between Minneapolis and Nashville, these
costs appear to be embodied in the asserted travel expenses
previously addressed.
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