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However, those financial outlays were not of the type considered
to be costs of maintaining a home such that the expenses related
to petitioners’ life on the road for Sheehan would be redundant.
Petitioners were not “away from home” within the intent and
meaning of section 162(a)(2) for the taxable years at issue
because they had no “home” to be away from. Barone v.
Commissioner, supra at 465; Wirth v. Commissioner, 61 T.C. 855,
858-859 (1974). In short, petitioners’ tax home was wherever
they happened to be. See Brandl v. Commissioner, supra.
Accordingly, petitioners are not entitled to deduct the expenses
claimed on their returns for the years at issue.
B. Section 6662(a)
Section 6662(a) imposes a penalty equal to 20 percent of the
amount of any underpayment attributable to negligence or
disregard of the rules or regulations. Sec. 6662(b)(1).
“‘[N]egligence’ includes any failure to make a reasonable attempt
to comply with the [Internal Revenue Code], and the term
‘disregard’ includes any careless, reckless, or intentional
disregard.” Sec. 6662(c).
In view of the factual uncertainties presented in this case,
as well as Mr. Ayala’s forthright and very credible testimony, we
are convinced that petitioners operated in good faith and that
the reasonable cause and good faith provisions of section
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