- 29 - 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 toPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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