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Warner v Prior¹, was one of the first cases concerning the deductibility of travel expenses under the post-1998 rules. In this case, it was decided that a supply teacher who carried out her non-teaching paperwork at home was not entitled to deduct from her emoluments her expenses of travelling from home to school. The facts were that the taxpayer (W), a supply teacher, had two places of work, namely her home office and the various schools in which she worked. Under the regulations determining a school teacher's pay and conditions, W was required to perform two types of duty; 'directed time' — actual teaching time; and 'additional time' — including marking, report writing and lesson preparation. Unlike the permanent teachers, she had no place of her own in the schools to work or keep papers and performed the bulk of her additional time in an office she maintained at home.

W travelled between her home and the various schools in which she worked in her own car and, in her self-assessment for 1999–2000, claimed a