- 39 - City, Missouri, where he resided for personal reasons to which his employment with the Kansas Air Force Reserve was incidental). In any event, the record provides no basis for determining what portion, if any, of petitioner’s rental expenses might be properly attributable to his presence in Nashville for the performance of business duties, as opposed to his presence there for personal reasons. We conclude and hold that the Nashville apartment rental and utilities expenses are not deductible travel expenses under section 162(a)(2). (iii) Nashville Meals and Incidental Expenses As previously discussed, the evidence in the record does not adequately substantiate the time, place, or business purpose of petitioner’s travel. Petitioner seems to suggest that with respect to the days he resided in Nashville, the time, place, and business purpose of his travel are substantiated because of his employment there with Flagship Airlines. We disagree, particularly as to the element of business purpose. As previously discussed, for the majority of taxable year 1991, petitioner’s sole personal residence was in Nashville. Petitioner failed to establish the requisite business purpose for his stays in Nashville. To the extent petitioner’s claim is predicated on travel expenses that might have been incurred in connection with his employment with Flagship Airlines while he was away from hisPage: 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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