William J. McNeill - Page 2




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          After concessions,1 the sole issue for decision is whether                  
          petitioner is entitled to deduct expenses for travel and meals              
          under section 162(a)(2).2                                                   
               The parties have stipulated some facts, which we incorporate           
          herein by this reference.  When he filed his petition, petitioner           
          resided in Crystal City, Missouri.                                          
                                     Background                                       
               During the years at issue, petitioner owned and operated a             
          long-haul, over-the-road truck.  He was on the road about 360               
          days in 1998 and about 345 days in 1999.                                    
               In 1998, petitioner spent 5 days at a house in Green Bay,              
          Wisconsin (the Green Bay house), which petitioner’s partner                 
          owned.  The major expense petitioner incurred at the Green Bay              



               1 On brief, respondent has conceded the sec. 6654 additions            
          to tax.  In his amended petition, petitioner alleged that                   
          respondent’s determination of tax set forth in the notice of                
          deficiency was erroneous because:  (1) The deficiencies in                  
          petitioner’s income taxes were not determined by an authorized              
          delegate of respondent; (2) the notice of deficiency was not sent           
          by an authorized delegate of respondent; (3) respondent’s                   
          deficiency determination was arbitrary; (4) petitioner’s self-              
          employment tax liability and corresponding deduction should not             
          have been increased for the tax years at issue; and (5)                     
          petitioner was entitled to claim an earned income credit for the            
          years at issue.  Petitioner did not pursue these issues at trial            
          or on brief; therefore, we deem petitioner to have abandoned                
          them.  See Burbage v. Commissioner, 82 T.C. 546, 547 n. 2 (1984),           
          affd. 774 F.2d 644 (4th Cir. 1985).                                         
               2 Unless otherwise indicated, section references are to the            
          Internal Revenue Code in effect for the years at issue.                     




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