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present on only one afternoon each week. Petitioner earned
significantly more of his income from his employment in
California than he earned from his private practice in Chicago,
Illinois. In addition, petitioner's employment in California was
not temporary. Petitioner's actual employment in the State
lasted over 3 years. See Rev. Rul. 83-82, 1983-1 C.B. 45 (actual
stay of over 2 years will be considered indefinite regardless of
facts and circumstances). Petitioner was hired by the county of
Riverside to set up the forensic unit at its jails, and he
testified that he expected the job to be of short duration based
on his experience with a similar job in Santa Monica which lasted
14 months. However, by his own admission petitioner was well
respected in Southern California, and his prospects for
employment within that area were of an indefinite, not temporary,
nature. See Ellwein v. United States, 778 F.2d 506 (8th Cir.
1985). Although petitioner maintained his residence in Chicago,
Illinois, we find that petitioner's principal place of business
during the year in issue was California. Therefore, petitioner
is not entitled to deduct the costs of lodging, meals, or other
expenses incurred in California, because these expenses were not
incurred while petitioner was away from home. Petitioner is
entitled to deduct the expense of traveling between California
and Chicago, Illinois.
Petitioner has substantiated airline expense of $640 by his
records and testimony. Petitioner has not established that he is
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