- 7 - appointment. Nothing in the record indicates that Queens College expressed any intention to limit the duration of petitioner's employment. Petitioners argue that a tenure-track position should be considered temporary because petitioner could be terminated after her nine-month appointment. The absence of permanence does not require a finding that petitioner's employment was temporary. Garlock v. Commissioner, 34 T.C. 611 (1960). An "employment which merely lacks permanence is indefinite unless termination is foreseeable within a short period of time." Kasun v. United States, 671 F.2d 1059, 1061 (7th Cir. 1982); Boone v United States, 482 F.2d 417, 419-420 (5th Cir. 1973) (This is the circuit to which this case is appealable). Regardless of whether there existed the possibility that petitioner would not be reappointed, we are convinced that petitioner had a reasonable expectation that her employment at Queens College would continue for a substantial or indefinite period of time. In fact, petitioner was offered continued employment at Queens College. However, she declined the offer. We conclude that petitioner's employment was indefinite, and, therefore, she was not away from her tax home. Petitioner'sPage: Previous 1 2 3 4 5 6 7 8 Next
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