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C. Travel Expenses
In general, expenses incurred for a taxpayer’s daily meals
and lodging and for commuting between the taxpayer’s residence
and the taxpayer’s place of business are nondeductible personal
expenses. Sec. 262(a); see, e.g., United States v. Correll, 389
U.S. 299 (1967); Commissioner v. Flowers, 326 U.S. 465, 472-473
(1946); Barry v. Commissioner, 54 T.C. 1210, 1214 (1970), affd.
per curiam 435 F.2d 1290 (1st Cir. 1970); see also secs.
1.162-2(e), 1.262-1(b)(5), Income Tax Regs. By contrast,
traveling expenses, including amounts expended for meals and
lodging, may be deducted if they are incurred while away from
home in the pursuit of a trade or business or related to
income-producing property.8 Secs. 162(a)(2), 212, 262.
1. Record Keeping
A taxpayer is required to maintain records sufficient to
establish the amount of his deductions. See sec. 6001; sec.
1.6001-1(a), Income Tax Regs. When a taxpayer establishes that
he paid or incurred a deductible expense but does not establish
the amount of the deduction, we may estimate the amount allowable
in some circumstances. Cohan v. Commissioner, 39 F.2d at 543-
544. There must be sufficient evidence in the record, however,
8For a taxpayer to be considered “away from home” within the
meaning of sec. 162(a)(2), the taxpayer must be on a trip that
requires the taxpayer to stop for sleep or a substantial period
of rest. United States v. Correll, 389 U.S. 299 (1967);
Strohmaier v. Commissioner, 113 T.C. 106, 115 (1999).
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