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Friedman v. Commissioner, 37 T.C. 539, 552 (1961). "An
individual may have a domicile in one place and a residence in
another, and may also have more than one residence." Id.
Residence does not mean one's permanent place of abode, where he
intends to live all his days or for an indefinite or unlimited
time; nor does it mean one's residence for a temporary purpose,
with the intention of returning to his former residence when that
purpose has been accomplished. Houlette v. Commissioner, 48 T.C.
350, 356 (1967); Stolk v. Commissioner, supra at 353.
When petitioner was in the San Francisco Bay area during the
work week, he stayed with his mother or friends or in a hotel.
Sleeping at his mother's or friends' homes is not enough to make
those locations petitioner's abode, nor did he intend to remain
there. His mother or friends could at any time change the locks
or otherwise exclude petitioner from the premises. Lacking any
actual dominion over the property, petitioner was merely a guest
at sufferance, and neither his mother's home nor his friends'
homes constitute petitioner's actual place of abode. Generally,
property is not "used by the taxpayer as his principal residence"
within the meaning of section 1034(a), unless the taxpayer
physically occupies and lives in the property. Perry v.
Commissioner, 91 F.3d 82, 85 (9th Cir. 1996), affg. T.C. Memo.
1994-247; Houlette v. Commissioner, supra; Stolk v. Commissioner,
supra.
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