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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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