Joe D. and Maura F. White - Page 11




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               The remaining expenses relate to petitioner's car and truck            
          expenses.  As noted earlier, petitioners claimed $938.43.  At               
          trial, respondent conceded petitioners' entitlement to a                    
          deduction of $100 for such expenses, leaving at issue $838.43.              
               The expenses claimed relate to petitioner's use of his                 
          vehicle in going to and from his home to each of the places where           
          he performed his services, including the use of his vehicle in              
          going from one business place to another business place.  The               
          $100 respondent conceded as a car expense represents the amount             
          respondent determined was incurred by petitioner in going from              
          one location of his business to other locations.  The remainder             
          represents petitioner's transportation expenses to and from his             
          home to each business location where he performed his self-                 
          employment activity.                                                        
               The Court finds it unnecessary to decide whether petitioner            
          substantiated the amount at issue.  Petitioner contends that,               
          because his home was his principal place of business, he is                 
          entitled to a deduction for car and truck expenses incurred from            
          his home to each place of business and his return home.                     
          Petitioners' home, however, was not his principal place of                  
          business; therefore, section 262 governs in this situation.  As a           
          general rule, section 262 disallows expenses for personal,                  
          living, or family expenses.  Transportation expenses ordinarily             
          incurred between one's residence and one's principal place of               





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