Discussion:Revenue Ruling 99 apply?

I have a client who works as a project manager for a land developer. He lives about 50 miles from the metro Atlanta area and lives 65 miles from his company's headquarters. He commutes to the headquarters once a week and otherwise will go to various company development sites the remainder of the week which are within the Atlanta metro area.

These are the mileage numbers he gave me for his personal truck:

Total miles driven in 2007: 65,880

Total business miles driven in 2007: 48,340

Total personal miles driven in 2007: 10,780

Total commuting miles driven in 2007: 6,760

My take is that he IS able to deduct his daily transportation miles between his home and these various temporary locations (and in between the various temporary locations). Rev. Rul. 90-23, 1990-1 C.B. 28, distinguishes Rev. Rul. 190 and holds, in part,that, for a taxpayer who has one or more regular places of business, daily transportation expenses paid or incurred in going between the taxpayer’s residence and temporary work locations are deductible business expenses under § 162(a), regardless of the distance.

Anyone disagree? This ruling is so full of noted exceptions and objections to the overrules noted stipulated exceptions that it is hard to fully understand the ruling. I believe that this client's circumstances are such that they apply to deductible mileage.

Thanks, Michael

I will pick up that Ernst and Young guide Southpark, money well spent.

Thanks,

Michael