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business, typically referred to as commuting expenses, are
nondeductible personal expenses under section 262. Fausner v.
Commissioner, 413 U.S. 838 (1973); Commissioner v. Flowers, 326
U.S. 465 (1946). The expenses at issue were incurred by
petitioner as commuting expenses and, therefore, are not
deductible.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011