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tions but instead returned in the evenings to petitioners’ resi-
dence in Keyser. Petitioners do not contend, and the record does
not establish, that during 2002 Mr. Shoemaker’s daily roundtrips
between petitioners’ residence and his claimed job site locations
required him to stop for sleep or a substantial period of rest.
See United States v. Correll, 389 U.S. 299 (1967); Strohmaier v.
Commissioner, 113 T.C. at 115.
On the instant record, we find that petitioners have failed
to carry their burden of establishing that during 2002 the ex-
penses relating to Mr. Shoemaker’s use of petitioners’ automobile
that petitioners claim he incurred while traveling from petition-
ers’ residence to his claimed job site locations were incurred
while he was away from home within the meaning of section
162(a)(2).
Although petitioners have failed to establish that the
expenses at issue relating to Mr. Shoemaker’s use of petitioners’
automobile were incurred while he was away from home within the
meaning of section 162(a)(2), as discussed above, petitioners may
nonetheless be entitled to deduct such expenses under section
162(a) if they were incurred for business, and not personal,
reasons. Petitioners concede that during 2002, and at all other
relevant times, they resided in Keyser solely for personal, and
not business, reasons. Petitioners do not contend, and the
record does not establish, that during 2002 Mr. Shoemaker worked
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