This is my homework from federal taxation class, can someone please help me figure out how to argue against IRS?

The learning and developmental goals of this assignment are to:

Provide an introduction to tax research and internet research related resources

Explore various web sites containing tax specific information

Think logically, creatively and succinctly in attaining a specific goal

Read critically, evaluate information and make a decision

Communicate your research results in an appropriate format

Research Problem:

Carlo Peterson worked in the HR Department of his employers, Acme Corporation, headquarters in San Francisco, CA for six years. Despite good job reviews, Carlo recently had major difficulty in working with the Director of the HR Department. The VP of Operations decided to have Carlo transferred to the Stockton, CA office with an understanding the transfer was temporary and he would return to the San Francisco headquarters after the current HR Director retired. The Directors retirement had been announced and she had four months left in her position.

Carlo lived in downtown San Francisco. It was about 80 miles to the Stockton office. During the next four months Carlo made eighty-five round trips from his home in San Francisco to Stockton. He kept track of his trips on a desk calendar and kept gas receipts. His actual presence in Stockton could be verified by Acme Corporation employee records.

After the HR Director retired and Carlos temporary assignment was completed, Carlo requested a transfer back to the San Francisco headquarters. The VP of Operations declined the transfer stating that Carlos former position had been filled by another person and there was no other position available. However, the VP of Operations offered Carlo a permanent position in Stockton. This was very unsatisfactory to Carlo and he quit.

Carlo deducted employee transportation expenses on his tax return. The IRS disallowed the deduction. The IRSs first objection was that Carlos position in Stockton was a permanent not a temporary position. They argued that he had changed his tax home from San Francisco to Stockton. This would make his transportation expenses nondeductible commuting expenses. The second IRS objection was that the transportation expenses were not properly substantiated. If not properly substantiated the expenses are not deductible.

Carlo is seeking your advice to see if there is some way his transportation expenses can be deducted.