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house was for the telephone. He paid no rent there and did not
contribute to mortgage payments.
In April 1998, petitioner agreed to buy a friend’s mobile
home in Bonne Terre, Missouri (the mobile home), making payments
of about $1,000 per year before receiving title to the mobile
home in 2001. In 1998 and 1999, petitioner paid no utilities or
maintenance expenses with respect to the mobile home. In 1998,
petitioner would stop at the mobile home only for a few hours
while reloading his truck. In 1999, petitioner spent about 20
days at the mobile home.
For each year at issue, petitioner filed a Form 1040, U.S.
Individual Income Tax Return. On Schedule C, Profit or Loss From
Business (Schedule C), attached to his 1998 return, petitioner
deducted $8,006 for travel expenses and $6,480 for meals
expenses. On Schedule C attached to his 1999 return, petitioner
deducted $5,799 for travel expenses and $5,760 for meals
expenses. In the notice of deficiency, respondent disallowed all
these claimed deductions.
Discussion
The cost of traveling, including food and lodging, is
generally considered a nondeductible personal expenditure. See
Deamer v. Commissioner, 752 F.2d 337, 338 (8th Cir. 1985), affg.
T.C. Memo. 1984-63. A deduction is allowed, however, for
ordinary and necessary business expenses, including “traveling
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