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Petitioner's position is that his "home" during 1993 was in
Chandler. He argues that he conducted research and writing
activities in the Chandler area during 1993 which he considered
his primary business activity. Respondent's position is that
petitioner's "home" during 1993 was in Calexico. Respondent
argues that petitioner is not entitled to the claimed deduction
because the expenses were not paid while he was away from home.
Based on the record, we find that petitioner's primary place
of business or employment, and thus his "home" under section
162(a)(2), was in Calexico. Petitioner earned his living as a
high school teacher in Calexico. We are not convinced that he
conducted research, writing, or other business activities in
Chandler which allow his teaching activity in Calexico to be
treated as other than his primary business activity. According
to his tax returns filed with respondent, he earned no income
from these other activities from 1991 through 1996. Moreover, we
find the actual time petitioner spent in Chandler during which
these activities could have been conducted insubstantial in
comparison to the actual time he spent teaching in Calexico. He
worked full-time in Calexico during the school year and testified
that he spent at least 1 month of his 2-month summer vacation in
Alaska with his son, George, in an activity for which he claimed
Schedule C business expense deductions which were allowed by
respondent. We find that he maintained his residence in Chandler
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