In 2005 and 2006, Glenn Bogue (plaintiff), a contractor, worked on five houses. Most of these houses were located in Pennsylvania, but none was located more than 20.1 miles away from Bogue’s New Jersey home. Bogue worked for several months on each house before beginning work on the next house. Bogue deducted the expenses for his car, truck, rental car, vehicle insurance, and road tolls as tax-deductible business expenses under § 162(a) of the federal tax code. The commissioner of internal revenue (commissioner) (defendant) determined that these expenses were nondeductible personal-commuter expenses under § 262(a) of the tax code, and disallowed the § 162(a) deductions. Bogue petitioned the tax court for a redetermination.