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Generally, “home”, as used in section 162(a)(2), is the
vicinity of the taxpayer’s principal place of employment and not
where his personal residence is located if the latter is located
at a distance from his employment. Coombs v. Commissioner, 608
F.2d 1269, 1274 (9th Cir. 1979), affg. in part and revg. in part
67 T.C. 426 (1976); Mitchell v. Commissioner, 74 T.C. 578, 581
(1980); Kroll v. Commissioner, supra at 561-562. An exception to
the general rule permits a taxpayer to deduct the costs of meals
and lodging incurred at a job site distant from his personal
residence if the job is temporary, rather than indefinite.
Peurifoy v. Commissioner, 358 U.S. 59, 60 (1958).
When a taxpayer accepts temporary work in a place away from
his residence, he may deduct the living expenses incurred at the
temporary post of duty, because it would not be reasonable to
expect him to move his residence under such circumstances. See
Tucker v. Commissioner, supra at 786. Employment is considered
to be temporary if termination within a short period could be
expected. Mitchell v. Commissioner, supra at 581. In contrast,
employment is considered indefinite if termination could not be
expected or foreseen within a fixed or reasonably short period of
time. Id. The duration of employment is a factual issue, and no
single element is determinative. Norwood v. Commissioner, 66
T.C. 467, 470 (1976).
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