- 9 - (1st Cir. 1984); Neal v. Commissioner, 681 F.2d 1157, 1158 (9th Cir. 1982), affg. per curiam T.C. Memo. 1981-407; Kasun v. United States, 671 F.2d 1059, 1061 (7th Cir. 1982); Williams v. Commissioner, T.C. Memo. 1990-467; Epperson v. Commissioner, T.C. Memo. 1985-382. In Epperson, the taxpayer was an ironworker who, during 1981, commuted daily to various job sites from his home in Seffner, Florida: Round trip Job site Number of days mileage from Seffner New Wales 92 44 Palatka 26 300 St. Petersburg 43 30 Crystal River 37 160 After finding that all of the jobs were temporary, rather than indefinite, we held that the taxpayer’s commuting expenses to the job sites in Palatka and Crystal River were deductible, but his commuting expenses to the job sites in New Wales and St. Petersburg were not deductible because they “were clearly within the general area of the petitioner’s residence”. Id. Other courts have likewise imposed a requirement that for a taxpayer’s commuting expenses to be deductible the taxpayer’s residence must be distant from the temporary job site. In Dahood v. United States, supra at 48, the Court of Appeals for the First Circuit explained the rationale for permitting the deduction of commuting expenses to temporary job sites: A judicial exception has been carved out of this general rule [that daily commuting expenses are not deductible] to cover instances when people commute long distances to their workplaces for business, rather thanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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