Treasury Regulations · 26 CFR
§ 1.274-14. Disallowance of deductions for certain transportation and commuting benefit expenditures.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 274
Cite as 26 CFR § 1.274-14
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- December 16, 2020 by T.D. 9939
- Issued under
- 26 U.S.C. § 274
- Length
- 464 words · about 2 min to read
- Defines
- 3 terms
- Cross-references
- cites 4 Code sections and 3 regulations; cited by 0
¶(a) General rule. Except as provided in this section, no deduction is allowed for any expense incurred for providing any transportation, or any payment or reimbursement, to an employee of the taxpayer in connection with travel between the employee's residence and place of employment. The disallowance is not subject to the exceptions provided in section 274(e). The disallowance applies regardless of whether the travel between the employee's residence and place of employment includes more than one mode of transportation, and regardless of whether the taxpayer provides, or pays or reimburses the employee for, all modes of transportation used during the trip. For example, the disallowance applies if an employee drives a personal vehicle to a location where a different mode of transportation is used to complete the trip to the place of employment, even though the taxpayer may not incur any expense for the portion of travel in the employee's personal vehicle. The rules in section 274(l) and this section do not apply to business expenses under section 162(a)(2) paid or incurred while traveling away from home. The rules in section 274(l) and this section also do not apply to any expenditure for any qualified transportation fringe (as defined in section 132(f)) provided to an employee of the taxpayer. All qualified transportation fringe expenses are required to be analyzed under section 274(a)(4) and § 1.274-13.
¶(b) Exception. The disallowance for the deduction for expenses incurred for providing any transportation or commuting in paragraph (a) of this section does not apply if the transportation or commuting expense is necessary for ensuring the safety of the employee. The transportation or commuting expense is necessary for ensuring the safety of the employee if unsafe conditions, as described in § 1.61-21(k)(5), exist for the employee.
¶(c) Definitions. The following definitions apply for purposes of this section:
¶(1) Employee. The term employee means an employee of the taxpayer as defined in section 3121(d)(1) and (2) (that is, officers of a corporate taxpayer and employees of the taxpayer under the common law rules).
¶(2) Residence. The term residence means a residence as defined in § 1.121-1(b)(1). An employee's residence is not limited to the employee's principal residence.
¶(3) Place of employment. The term place of employment means the employee's regular or principal (if more than one regular) place of business. An employee's place of employment does not include temporary or occasional places of employment. An employee must have at least one regular or principal place of business.
¶(d) Applicability date. This section applies to taxable years beginning on or after December 16, 2020.
[T.D. 9939, 85 FR 81408, Dec. 16, 2020]
Terms defined here
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Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 274 Disallowance of certain entertainment, etc., expenses
- § 162 Trade or business expenses
- § 132 Certain fringe benefits
- § 3121 Definitions
Regulations it cites
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9939 (85 FR 81408)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Items Not Deductible
Nearby sections
- § 1.274-10 Special rules for aircraft used for entertainment.
- § 1.274-11 Disallowance of deductions for certain entertainment, amusement, or recreation expenditures paid or incurred after December 31, 2017.
- § 1.274-12 Limitation on deductions for certain food or beverage expenses paid or incurred after December 31, 2017.
- § 1.274-13 Disallowance of deductions for certain qualified transportation fringe expenditures.
- § 1.274-14 Disallowance of deductions for certain transportation and commuting benefit expenditures.
- § 1.275-1 Deduction denied in case of certain taxes.
- § 1.276-1 Disallowance of deductions for certain indirect contributions to political parties.
- § 1.278-1 Capital expenditures incurred in planting and developing citrus and almond groves.
- § 1.279-1 General rule; purpose.