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IV. Schedule C Deductions
A. Parking Fees
Petitioner’s alleged parking fees constituted cash payments
for daily parking in downtown Houston parking lots. They were
incurred in connection with trips to court in pursuance of his
litigation practice. Respondent has denied petitioner’s
deduction of those fees for lack of substantiation.
Based upon petitioner’s testimony that, during the audit
years he “handled multiple cases * * * that required * * * [him]
to come to court most every day downtown”, we find that the
downtown Houston courthouses in which he litigated constituted
regular places of business.
It is well settled that the cost of commuting between one’s
residence and a regular place of business or employment is a
nondeductible personal expense. Commissioner v. Flowers, 326
U.S. 465, 473-474 (1946); sec. 1.162-2(e), Income Tax Regs.; sec.
1.262-1(b)(5), Income Tax Regs. Transportation expenses incurred
on trips between places of business, however, may be deductible.
Steinhort v. Commissioner, 335 F.2d 496, 503-504 (5th Cir. 1964),
affg. and remanding T.C. Memo. 1962-233. Here, the record does
not indicate which, if any, of petitioner’s trips to court
represented travel between his office and the courthouse or
between courthouses, nor is any amount associated with such
travel. Under such circumstances, none of petitioner’s trips to
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