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(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 Kansas
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