Lee E. Daly and Rosemarie H. Daly v. Commissioner of Internal Revenue

SPROUSE, Circuit Judge:

Following a Notice of Deficiency, the taxpayers, Lee and Rosemarie Daly, filed a petition in the United States Tax Court contesting the disallowance of deductions for certain meal, lodging, and travel expenses in their 1975 income tax return. The Commissioner had disallowed the deduction of expenses incurred by Lee Daly in traveling from his residence in McLean, Virginia, to Philadelphia, Pennsylvania, (the center of his income-producing activities), on the basis that Philadelphia was his tax home. The Tax Court agreed that Daly’s tax home was Philadelphia, finding that…