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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's
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