Elizabeth H. and Albert B. Turner - Page 6

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          home which is temporary, as opposed to indefinite, in duration.             
          Peurifoy v. Commissioner, 358 U.S. 59, 60 (1958).  If the                   
          employment is temporary, the tax home is considered to be the               
          place of the taxpayer's residence; whereas, if the employment is            
          indefinite, the tax home is the location of employment.  Kroll v.           
          Commissioner, supra at 562.  Employment is considered to be                 
          temporary if termination within a short period could be expected.           
          Mitchell v. Commissioner, supra at 581; Tucker v. Commissioner,             
          55 T.C. 783, 786 (1971).  In contrast, employment is considered             
          indefinite if termination could not be expected or foreseen                 
          within a fixed or reasonably short period of time.  Mitchell v.             
          Commissioner, supra at 581.  This expectation is measured by what           
          was contemplated at the time employment was accepted.                       
          McCallister v. Commissioner, 70 T.C. 505, 509 (1978).  The                  
          duration of employment is a factual issue, and no single element            
          is determinative.  Norwood v. Commissioner, 66 T.C. 467, 470                
          (1976).                                                                     
               Based on this record, we conclude that petitioner's                    
          employment at Queens College was indefinite in 1991.  Petitioner            
          had been employed previously by Queens College.  During 1991,               
          petitioner was employed as a full-time assistant professor at               
          Queens College.  It was a tenure-track position.  Under the terms           
          of her contract, tenure may be granted after a designated                   
          probationary period.  A grant of tenure confers continuous                  





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