Bamidele Arike Kolapo - Page 7

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          which she wrote from memory after she found out her returns were            
          going to be audited.                                                        
               First, we will address petitioner’s vehicle expenses.                  
          Expenses for transportation between a taxpayer’s residence and              
          his or her place of business or employment are generally                    
          considered personal expenses, the deduction of which is                     
          prohibited by section 262.  See Fausner v. Commissioner, 413 U.S.           
          838 (1973); Commissioner v. Flowers, 326 U.S. 465 (1946); secs.             
          1.162-2(e), 1.262-1(b)(5), Income Tax Regs.  However, the costs             
          of going from one business location to another generally are                
          deductible under section 162(a).  Rev. Rul. 55-109, 1955-1 C.B.             
               Petitioner worked in Franklin Lake during only 3 months per            
          year in 2003 and 2004 and testified that, even then, she worked             
          there only two or three times a week.  Yet petitioner’s logs                
          indicate that she drove 420 miles between her home and Franklin             
          Lake during every week of 2003 and 2004.  At trial, petitioner              
          acknowledged her mileage logs were incorrect but failed to                  
          elaborate on that acknowledgment.  She argued that when she                 
          worked in Franklin Lake, she drove from her home to Parsippany              
          and then from Parsippany to Franklin Lake but never directly from           
          her home to Franklin Lake.  However, petitioner was unsure of               
          herself and unclear when she tried to explain the mileage                   

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