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Milwaukee job nor evidence indicating that Mr. Wasik even would
have known the substance of the negotiations or how they were
proceeding. Moreover, even assuming the union representatives
did ultimately agree with NWA that NWA would add new mechanic
jobs in Minneapolis at some future time, these jobs would likely
also be subject to the seniority system. Thus, Mr. Wasik would
have no way to know whether he would be senior enough to obtain
one of the Minneapolis jobs if and when the Minneapolis jobs were
made available at some future, unknown date. The Court also
takes judicial notice that union negotiations did not prevail.
Mr. Wasik’s return to Minneapolis was not foreseeable because of
the prospect of union negotiations.
We conclude there was no business reason for petitioners to
maintain a home in the Minneapolis area. Petitioners kept the
family residence in the Minneapolis area for purely personal
reasons. Accordingly, Mr. Wasik was not away from home in
Milwaukee, and the expenses he incurred while there are not
deductible.
We next examine petitioners’ argument that they are entitled
to deduct vehicle expenses Mr. Wasik incurred traveling to Duluth
for training before beginning the Milwaukee position. Respondent
focuses his arguments on brief on the Milwaukee position and
fails to address whether Mr. Wasik was away from home while he
was training in Duluth. Respondent acknowledges that NWA
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