Bobby Walraven and Katherine Walraven v. Commissioner of Internal Revenue

Bobby Walraven and Katherine Walra-ven appeal from a tax court 1 decision upholding the income tax deficiencies determined by the Commissioner of Internal Revenue for their tax years 1980,1981, and 1982. We affirm.

I. BACKGROUND

Taxpayer Bobby Walraven 2 worked for three years at the Callaway nuclear power plant project (Callaway) near Fulton, Missouri. This was approximately 150 miles from his residence in Independence, Missouri. When filing U.S. federal income tax returns for 1980, 1981, and 1982, taxpayer deducted as business expenses under 26 U.S.C. § 162 (1982) the expenses incurred while…