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for overtime work. The preparer calculated the total expense
deduction.
Petitioner introduced 69 Inspection Overtime Forms and 12
monthly printouts of a computer calendar for 2003. The Court
finds that petitioner worked the overtime shifts reflected on the
Inspection Overtime Forms. The monthly computer calendar
printouts purport to substantiate the dates, overtime hours,
locations, and miles driven for petitioner’s overtime shifts.
Petitioner drove to various locations for overtime work,
including BWI, his usual place of business. He typically
returned home before and after performing overtime inspections at
other locations. He rarely drove directly from BWI to a second
work location.
Petitioner did not identify the overtime shifts for which he
drove directly from one work location to a second work location.
Instead, he contends that all transportation for overtime is
deductible if outside his usual commute. Transportation expenses
for trips between two places of business are deductible, but
transportation to and from work, whether for a regular shift or
for an overtime shift, is a nondeductible personal commuting
expense. See Curphey v. Commissioner, 73 T.C. 766, 777 (1980).
Furthermore, petitioner admitted that DHS reimbursed him for
transportation expenses and that DHS provided a Government car
for trips between BWI and the seaport for ship inspection
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