- 38 - (ii) Nashville Rent From March 1991 and at all relevant times thereafter, petitioner maintained his personal residence in Nashville, where he rented and furnished an apartment; as far as the record reveals, he maintained no regular living quarters in Minneapolis (his tax home). Petitioner seeks deductions for his Nashville rent and utility expenses. As far as the record reveals, petitioner’s decision to maintain his personal residence at his minor employment post in Nashville rather than near his principal place of business in Minneapolis was a personal choice made for the sake of his own convenience. Such a decision does not operate to convert personal living expenses into deductible business expenses. See Mazzotta v. Commissioner, 57 T.C. 427 (1971), affd. without published opinion 465 F.2d 1399 (2d Cir. 1972); Lagrone v. Commissioner, supra. There is no evidence in the record to indicate that Flagship Airlines required petitioner to live in the Nashville area. In this regard, this case is less like Folkman v. United States, 615 F.2d 493 (9th Cir. 1980) (allowing commercial pilot’s travel expenses between his San Francisco, California, airline duty post and Reno, Nevada, where he resided as a condition of retaining employment with the Nevada Air National Guard), upon which petitioner relies, than Dean v. Commissioner, T.C. Memo. 1976-379 (disallowing commercial pilot’s travel expenses between his New York airline duty post and KansasPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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