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The term “metropolitan area”, for purposes of deducting
daily transportation expenses under the exception found in Rev.
Rul. 99-7, supra, is not defined in that revenue ruling or the
prior revenue rulings on the subject.12 Courts that have
addressed the issue have generally looked at whether the work
site in question was within the general area of the taxpayer’s
principal or regular place of employment, see Harris v.
Commissioner, supra (for transportation expenses to be
deductible, the taxpayer must prove that temporary work sites are
outside the general area of the taxpayer’s principal or regular
place of employment); see also Aldea v. Commissioner, T.C. Memo.
2000-136; Carter v. Commissioner, T.C. Memo. 1988-189, as well as
the distance between the work site and the taxpayer’s residence,
see Ellwein v. United States, 778 F.2d 506, 511-512 (8th Cir.
1985) (daily transportation costs deductible only if the
temporary employment is outside the area of the taxpayer’s
regular abode); Dahood v. United States, 747 F.2d 46, 48 (1st
Cir. 1984); Boehmer v. Commissioner, T.C. Memo. 1986-315.
With this background in mind, we believe it is appropriate
to interpret “metropolitan area”, as that term is used in Rev.
11(...continued)
regular place of employment. We thus found, without deciding
whether the jobs were temporary, that the taxpayer was not
entitled to deduct the transportation expenses at issue.
12 Rev. Rul. 94-47, 1994-2 C.B. 18; Rev. Rul. 90-23, 1990-
1 C.B. 28; Rev. Rul. 190, supra.
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