Al Hardee has been employed as a salesman by Robin Chevrolet at its Milwaukee dealership. In early May, Al and the general manager of the office had a serious dispute over job procedures. When it became clear that the two could no longer work together amicably, Al contacted Robins CEO regarding a possible solution. As the general manager planned to retire in five months, it was decided that Al would spend this period working at the Green Bay branch. After the managers retirement, Al was to rejoin the Milwaukee office. Als residence is only a few blocks from the Milwaukee office, but it is 96 miles (one way) from the Green Bay worksite. During the next five months (i.e., May to October), Al made 120 trips driving from his home in Milwaukee to the Green Bay job. Upon termination of the five-month assignment and after the retirement of the general manager, Al requested a transfer back to the Milwaukee office. The CEO turned down the request on the grounds that Al was no longer needed in Milwaukee. During his absence and unknown to Al, his job position in Milwaukee had been eliminated. However, the CEO offered to make the Green Bay assignment permanent. Hurt and disgusted, Al quit and took a job with a competing Milwaukee car dealership. On his Federal income tax return, Al claimed a deduction for employee transportation expenses, computed as follows: 120 (number of trips) x 192 (round-trip mileage) x automatic mileage rate for the year. The IRS disallowed the deduction on the grounds that Als job status in Green Bay was permanent and not temporary. Thus, his tax home had changed from Milwaukee to Green Bay. This, in turn made his transportation expenses nondeductible commuting expenses.

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