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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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Last modified: March 27, 2008