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the taxpayer did not reside in the household at issue--not only
in W.E. Grace v. Commissioner, supra, but also in later cases,
see Williams v. Commissioner, 53 T.C. 58 (1969) (Clair Smith
distinguished, and head-of-household status denied on the grounds
that the taxpayer had never lived in his adopted son's house),
affd. per curiam 441 F.2d 1168 (9th Cir. 1971); Biolchin v.
Commissioner, T.C. Memo. 1969-197 (head-of-household status
denied because the taxpayer did not physically occupy his former
wife's house), affd. per curiam 433 F.2d 301 (7th Cir. 1970).
Other Courts have used a similar approach to distinguish Clair
Smith, and to hold that a house in which the taxpayer does not
reside is not the taxpayer's home for purposes of the head-of-
household provisions. See, e.g., Muse v. United States, 434 F.2d
349 (4th Cir. 1970).
On the basis of our head-of-household decisions--and our
judgment about the ordinary meanings of words--we believe that a
foster care provider must reside in a house or other residential
structure, before that structure can qualify as “the foster care
provider's home” for purposes of section 131.
We are well aware that we have interpreted other provisions
of the Code as not always requiring “home” to have a residential
connection. In particular, section 162(a)(2) provides for the
deduction of business travel, meal, and lodging expenses incurred
while the taxpayer is “away from home”. We have long taken the
position that a taxpayer's “home” for purposes of this provision
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