On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Johnson v. Commissioner (T.C. Memo. 2020-79). The issues before the court in Johnson v. Commissioner were (1) whether the petitioner is entitled to deduct certain expenses on his Schedules F (Profit or Loss from Farming) for the years in issue; and (2) the valuation of a conservation easement. Driving Between Two Places of Business Deductible (if One is Not Your House) Generally, expenses that a taxpayer incurs in commuting between his home and his place of business are personal and nondeductible. See Commissioner v. Flowers, 326 U.S. 465, 473-474 (1946); Heuer v. Commissioner, 32 T.C. 947, 951 (1959), aff’d per curiam, 283 F.2d 865 (5th Cir. 1960); Treas. Reg. § 1.162-2(e); Treas. Reg. § 1.262-1(b)(5). However, expenses incurred for traveling between two or more places of business may be deductible as ordinary and necessary business…