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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 his
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