Michael L. and Ann Burski - Page 17




                                        -16-                                          
          Petitioner’s tax home for the years at issue was Alexandria,                
          Virginia.                                                                   
               The car and truck expenses and any claimed depreciation for            
          using his car were petitioner’s personal expenses for driving               
          between his residence in Lancaster and his work in Alexandria.              
          The travel expenses and utilities were for his lodging when he              
          stayed in Alexandria, and the meals and entertainment expenses              
          were his costs of meals and entertainment incurred when he stayed           
          in Alexandria.  Petitioner did not incur the disallowed expenses            
          while away from his tax home in the course of his trade or                  
          business.                                                                   
               We hold that petitioners are not entitled to deduct the                
          disputed items.                                                             
               To reflect the foregoing and the parties’ concessions,                 

                                                  Decision will be entered            
                                             under Rule 155.                          



















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