- 10 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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