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Petitioner did not report any income on his 1998 Schedule C.
Petitioner indicated on his Schedule C that his principal
business or profession was “Online publishing”.
Petitioner calculated the $7,552 in car expenses by
multiplying the 21,545 claimed business miles by $0.325 per mile
(equals $7,002), to which he added an amount for parking and
tolls.
Respondent determined that petitioner failed to report $75
of nonemployee compensation income but now agrees that petitioner
properly included said amount as part of his reported wages of
$54,640.
OPINION
Generally, taxpayers are not allowed to deduct the daily
cost of commuting to and from work, as such expense is considered
to be personal and nondeductible. Commissioner v. Flowers, 326
U.S. 465, 473-474 (1946); sec. 1.162-2(e), Income Tax Regs. One
exception from that general rule involves situations where the
transportation is to and from a temporary work location. See,
Rev. Rul. 90-23, 1990-1 C.B. 28, as amplified and clarified by
Rev. Rul. 94-47, 1994-2 C.B. 18, as modified by Rev. Rul. 99-7,
1999-1 C.B. 361.
Under the above-cited revenue rulings, taxpayers are
permitted deductions for daily transportation expenses incurred
in going between a taxpayer’s residence and a temporary work
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