Gary M. and Trudy J. Weichlein - Page 16

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             Petitioner's only employer from 1988 through all of 1990 was             
        Fontana or its sister corporation, Vernon.  While petitioner did              
        work in Anaheim for a short period, she spent a majority of taxable           
        year 1990 in Victorville.  We find that petitioner's principal place          
        of business in 1990 was Victorville, California.  However, because            
        she lacked any business ties to Catheys Valley, she was not "away             
        from home" when she was living and working in the Victorville area.           
        See Tucker v. Commissioner, 55 T.C. 783, 787 (1971).                          
             Petitioner maintains that her employment with Fontana in the             
        Victorville area was temporary because she intended to remain in the          
        area for a short period of time.  In addition, petitioner contends            
        that she worked at a series of temporary jobs, always returned to             
        Catheys Valley whenever possible, and had maintained a residence in           
        Catheys Valley since 1978.  However, because she has failed to show           
        that she had any business prospects or ties in Catheys Valley, her            
        work in Victorville did not take her "away from home" for purposes            
        of section 162(a)(2).                                                         
        Petitioner's ownership of a residence in Catheys Valley is not                
        enough to justify a decision in petitioner's favor.  To do so would           
        place petitioner's home where her heart lies and render section               
        162(a)(2) a vehicle by which to deduct the full spectrum of one's             
        personal and living expenses.  See Bochner v. Commissioner, 67 T.C.           
        824, 828-829 (1977).  Petitioner's decision to retain her residence           

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