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alia, Jan. 1 through Sept. 30, 2002); Rev. Proc. 2002-63, secs.
3.02(1)(a), 4.03, 2002-2 C.B. 691, 693-694 (applicable to, inter
alia, Oct. 1 through Dec. 31, 2002). The use of the M&IE estab-
lishes only the daily amount deemed spent for meals while travel-
ing away from home on business. Sec. 1.274-5(j)(1), Income Tax
Regs. The taxpayer must still establish the time, the place, and
the business purpose of the daily expenditures for meals. Id.
In support of the deductions that petitioner claims for his
taxable year 2002 for expenditures for the use of his automobile,
lodging, meals, and certain unidentified travel purposes, peti-
tioner testified that during that year he worked in North
Carolina and Pennsylvania.7 In support of his testimony, peti-
tioner relies on a document (document one) that his certified
public accountant prepared sometime after the Internal Revenue
Service contacted petitioner regarding petitioner’s 2002 tax
return. Document one purports to list the job site locations at
which petitioner claims he worked during 2002 (i.e., West Jeffer-
son, North Carolina, and Wind Gap, Pennsylvania), the respective
time periods during which he claims he worked at such locations,
and the respective round-trip mileages from Core, West Virginia,
to such locations. The record does not establish where peti-
tioner resided during the periods in 2002 when petitioner claims
7Petitioner did not identify during his testimony the loca-
tions in N.C. or Pa. where he claims he worked during his taxable
year 2002.
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