Sanders v. Commissioner

JAMES M. CARTER, Circuit Judge.

Taxpayers appeal from the decision of the Tax Court1 upholding the Commissioner’s determination that their automobile expenses are commuting expenses which are not deductible under § 162 of the Internal Revenue Code of 1954. Their appeal raises the issue of whether taxpayers who commute by automobile between their residences and permanent places of employment are entitled to deduct, under § 162, automobile expenses attributable to travel between their work-sites and the closest habitable communities. We agree with the decision of the Tax Court that such expenses…