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amount of expenses that petitioners are claiming for each cate-
gory of expense at issue. Mr. Shoemaker testified that petition-
ers’ accountant prepared document two after the Internal Revenue
Service contacted petitioners to request documentation regarding
petitioners’ 2002 return. We shall not rely on document two to
establish petitioners’ position with respect to any of the ex-
penses for which they claim deductions for 2002.12
Claimed Automobile Expenses
In general, expenses relating to the use of an automobile
that a taxpayer pays or incurs while commuting between the tax-
payer’s residence and the taxpayer’s place of business or employ-
ment are not deductible under section 162(a). See, e.g., Commis-
sioner v. Flowers, 326 U.S. at 472-473; see also secs. 1.162-
2(e), 1.262-1(b)(5), Income Tax Regs. Nonetheless, such expenses
may be deductible under section 162(a) where paid or incurred
“away from home”, sec. 162(a)(2), or, even if not paid or in-
curred away from home within the meaning of section 162(a)(2),
where paid or incurred for business, and not personal, reasons.13
Petitioners concede, and we have found, that during 2002 Mr.
Shoemaker did not stay overnight at his claimed job site loca-
12To the extent that other evidence corroborates the respec-
tive listings shown in document two for each category of expense
at issue, we shall address below such corroborative evidence.
13See, e.g., Daiz v. Commissioner, T.C. Memo. 2002-192;
Epperson v. Commissioner, T.C. Memo. 1985-382.
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