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as the choices of more senior mechanics. Petitioner did not know
how long he would be in Milwaukee or Detroit or where he might go
next. It was not foreseeable that he would be able to return to
Minneapolis at any time due to the seniority system. Thus, there
was no business reason for petitioner to maintain a home in the
Minneapolis area. Petitioner kept the residence in the
Minneapolis area for purely personal reasons. Petitioner has
failed to prove that he had a tax home in 2003. Accordingly,
petitioner was not away from home in Milwaukee or Detroit, and
the expenses he incurred while there are not deductible.5
Substantiation of Expenses
We next turn to the substantiation issues to determine
whether petitioner is entitled to deduct any remaining expenses.
We begin by noting the fundamental principle that the
Commissioner’s determinations are generally presumed correct, and
the taxpayer bears the burden of proving that these
determinations are erroneous.6 Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290
U.S. 111 (1933). Moreover, deductions are a matter of
5Even if we had found that petitioner’s tax home during 2003
was Savage, Minnesota, petitioner may not be treated as
temporarily away from home while he worked in Detroit because the
position lasted over a year. See sec. 162(a).
6Petitioner does not claim the burden of proof shifted to
respondent under sec. 7491(a). Petitioner also did not establish
he satisfies the requirements of sec. 7491(a)(2). We therefore
find that the burden of proof remains with petitioner.
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