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To be deductible, traveling expenses must be substantiated
by adequate records or sufficient corroborating evidence. Sec.
274(d).
Before 2002, Mr. Lease regularly worked out of the
Cumberland, Maryland, union hall and was assigned jobs that were
within 50 miles of his residence. For 2002, there were fewer
jobs available from the Cumberland, Maryland, union hall and he
was forced to accept jobs outside of his principal place of
employment, some from a distant union hall that he had not
previously used. Each of the jobs outside of his principal place
of employment was of short duration.
Considering the record as a whole, we hold that Mr. Lease’s
2002 travel was outside of his usual and principal place of
employment and was both temporary and forseeably terminable. Mr.
Lease’s travel log was stipulated by the parties and meets the
substantiation requirements of section 274(d). Mr. Lease’s costs
for daily transportation outside of his metropolitan area where
he normally worked are deductible within the meaning of Rev. Rul.
99-7, 1999-1 C.B. 361. Accordingly, petitioners are entitled to
deduct travel expenses of $3,934 for 2002.
Although it is likely that Mr. Lease incurred meal expenses
during 2002, no substantiation or sufficient corroborating
evidence was offered that would meet the substantiation
requirements of section 274(d). Moreover, Mr. Lease normally
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