Bryan J. and Christine N. Baugh - Page 10

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               While petitioners’ subjective intent is to be considered in            
          determining whether they have a tax home,                                   
               objective financial criteria bear a much closer                        
               relationship to the underlying purposes of the                         
               deduction than do various other indicia of residence                   
               evidencing merely a taxpayer’s subjective opinion                      
               regarding the location of his home.  * * *  [Brandl v.                 
               Commissioner, supra at 699-700.]                                       
          See also Markey v. Commissioner, 490 F.2d 1249, 1255 (6th Cir.              
          1974), revg. T.C. Memo. 1972-154.                                           
               At trial, petitioners testified to their maintenance of                
          voter registrations, car registration, and driver’s licenses in             
          Port Clinton as an indication of their intent to make Port                  
          Clinton their tax home.  Petitioners both testified regarding               
          their intent to make Port Clinton their home, but petitioners’              
          tax home is not where their hearts lie.  See Bochner v.                     
          Commissioner, supra at 828-829.  The significance that                      
          petitioners ascribe to Port Clinton is not dispositive of whether           
          petitioners’ tax home, within the meaning of section 162(a)(2),             
          is Port Clinton.  See Markey v. Commissioner, supra.                        
               Petitioners provided little evidence that would indicate               
          that they incurred duplicate living expenses in maintaining                 
          414-1/2 Monroe.  No evidence was presented to show that                     
          petitioners ever set up house at 414-1/2 Monroe, such as the                
          purchase of appliances, other household goods, or even groceries.           
          See Rambo v. Commissioner, 69 T.C. 920, 922 (1978).  Petitioners’           
          only testimony at trial to this effect was their use of                     





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