- 6 -
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.
261.
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: November 10, 2007