Albert Camus has been employed as a statutory employee salesman by Algier Chevrolet at its Milwaukee dealership.In

early May, Albert and the general manager of the office had a serious dispute over job procedures.When it became clear they could not work together ,Albert contacted Algier's CEO about a possible solution.As the general manager planned to retire in five months ,it was decided Albert would work at the Green Bay branch during this period.After the manager's retirement ,Camus was to rejoin the Milwaukee office.

Albert's residence is nly a few blocks from the Milwaukee office, but its 96 miles from the green Bay worksite.During the next five months,May to October he made 120trips driving from his home in Milwaukee to his Green Bay job.His only records of the trips are a wall calendar with the work days circled and the credit card receipts from gasoline purchases.The employee records of the Green Bay Dealership,However, support Albert's on-the-job presence.

After the five month assignment ended and the general manger retired,Albert requested a transfer back to Milwaukee office. The CEO turned it down because he said Albert was no longer needed in Malwaukee. Apparently, his job position in Malwaukee had been eliminated in his absence. However, the CEO offered to make the Green Bay position permanent.Hurt and disgusted, Camus accepted a position with a competing Milwaukee car dealership.

On his federal income tax return,Albert claimed a deduction for transportation expenses, computed as follows 120 tripsX 192 round trip mileage X automatic mileage rate for the year.The IRS disallowed the deduction on two grounds.First, Albert's job status in Green Bay was permanent not temporary.Thus his tax home had changed from Malwaukee to Green Bay. So his transportation became nondeductible commuting expenses.Second even if his transportation was warranted, the expenses were not properly substantiated, precluding any tax deduction.

Albert Camus has come to you for Advice, can he be allowed a deduction for his transportation expenses?