Haig Simmons was just hired by B&B Restaurants, Inc., a Delaware Corporation domiciled in Colorado. Ms. Simmons maintains a residence in Orange County, California, so her children may attend the schools of her choice and so that her husband may be employed there as a leading plastic surgeon. B&B has just opened three (3) restaurants in Utah, Nevada, and Idaho. B&B requires Ms. Simmons set up the general ledger accounting system at each restaurant. B&B estimates it will take Ms. Simmons 14 months of continuous, full time work (40 hours per week, 4 weeks per month) to set up the systems. B&B requires Ms. Simmons to rotate her time. That is, to spend time at each restaurant at least once a calendar quarter. Each restaurant has an office for the accounting function, although the offices are so small that Ms. Simmons does a majority of her work from hotel rooms near the restaurants. Ms. Simmons reports back electronically to B&B. Ms. Simmons is never required to go to Colorado. B&B does not reimburse Ms. Simmons for her lodging, travel, or meal expenses. May Ms. Simmons deduct lodging, travel, and meal expenses? Note 1: Ignore limitations and phase-outs and cut backs and whether the putative deductions might be above the line or below the line. Ignore AMT. Note 2: This is your chance to show the research skills you've learned. You must cite the relevant code section(s), and at least three Supreme Court cases.

Subject (one line here) Facts (Taxpayer xxx. Xxx. Xxxx.) Rule of Law Issue (May taxpayer deduct xxxxxxx?) Conclusion (In this situation, xxxxxx.) Analysis (Code section xx(a) contains.....It states....... Reg. sec. clarifies.....Rev Ruling.....Court case XXX vs. XXXX holds that.....)