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Barracuda. In the notice of deficiency, respondent disallowed
$8,737 of the claimed basis in the Barracuda.
As a result of these adjustments, respondent made
computational adjustments to petitioners' itemized deductions for
each of the years at issue.
The first issue is whether, for each of the years at issue,
petitioners are entitled to deduct travel expenses in connection
with petitioner's air racing activity. The parties have agreed
that petitioner's tax home for the years at issue was not San
Diego but, rather, was either Miami, Chicago, or Seattle during
those years.2
Petitioner conducted his air racing activity in San Diego
during each of the years at issue. Therefore, petitioner
deducted away-from-home travel expenses for each day that he was
in San Diego during the years at issue. These included expenses
for lodging, meals, and incidental expenses while in San Diego
but did not include a deduction of expenses for travel to and
from his various tax home locations and San Diego. Rather than
deducting his actual expenses in San Diego, petitioner elected a
2 A "home" for purposes of sec. 162(a)(2) means the
vicinity of the taxpayer's principal place of business rather
than the personal residence of the taxpayer, when the personal
residence is not in the same vicinity as the place of employment.
Mitchell v. Commissioner, 74 T.C. 578, 581 (1980); Daly v.
Commissioner, 72 T.C. 190, 195 (1979), affd. en banc 662 F.2d 253
(4th Cir. 1981).
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