Billy J. Neal and Judith A. Neal v. Commissioner of Internal Revenue

The Neals appeal from a Tax Court decision upholding a determination by the Commissioner of Internal Revenue that taxpayer was not entitled to deduct transportation expenses, incurred in commuting by automobile between his personal residence and his place of employment, as business expenses under Section 162(a) of the Internal Revenue Code of 1954. The Tax Court had jurisdiction over this matter under Section 7442 of the Internal Revenue Code of 1954 and jurisdiction is conferred on this court by Section 7482.

Billy J. Neal 1 (taxpayer) was hired on March 14, 1977, by the Bechtel Power…