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when the petition was filed.2 Pursuant to section 7463(b), the
decision to be entered is not reviewable by any other court, and
this opinion shall not be treated as precedent for any other
case. Respondent determined a $2,403 income tax deficiency for
the 2002 tax year of David B. and Kathy A. Lease. The deficiency
was predicated on the disallowance of several deductions, and
after concessions the issues we must decide are whether Mr.
Lease’s expenses of driving to and from his work locations are
deductible and/or whether his meal expenses are deductible.
Background
Some of the facts have been stipulated and are incorporated
by this reference. At the time the petition was filed Mr. and
Mrs. Lease resided in West Virginia. Mr. Lease, now deceased,
was employed as a millwright during 2002. His jobs were assigned
at his local union hiring hall in Cumberland, Maryland. Every
week Mr. Lease would go to the union hall and sign up for work in
the “workbook”. The union representative would call when a job
was available, and Mr. Lease would then proceed from his locality
to his work. Many jobs were within a 50-mile radius, but during
2002 local jobs were scarce, and his work assignments expanded to
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 2002, the taxable year in
issue, and Rule references are to the Tax Court Rules of Practice
and Procedure.
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Last modified: March 27, 2008