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traveling to and living at his place of employment unless the
traveling is required by the exigencies of his employment, rather
than by his "personal conveniences and necessities".
Commissioner v. Flowers, supra at 474. There, the taxpayer's
principal place of employment was Mobile, Alabama, and the
taxpayer traveled to Mobile from his home in Jackson,
Mississippi, whenever his work required him to be in Mobile. The
Court found that this travel was not required by the exigencies
of his employment, but resulted from his personal choice to live
in Jackson. Since his principal employment was in Mobile, he
could reasonably have been expected to move there, which would
have made this travel unnecessary.
The principles articulated in Flowers have subsequently been
applied in other cases. From these cases, we understand that a
taxpayer's principal place of business generally is his or her
tax home, although his or her residence is in another city or is
not in the same area as the place of employment. See Mitchell v.
Commissioner, 74 T.C. 578, 581 (1980); Kroll v. Commissioner,
supra at 561-562. The rule is different, however, where a
taxpayer's employment in another area is temporary as opposed to
indefinite. See Peurifoy v. Commissioner, 358 U.S. 59 (1958);
Horton v. Commissioner, 86 T.C. 589, 593 (1986). A taxpayer's
tax home is his or her residence if the employment is temporary;
the taxpayer's presence at the other location is considered to be
away from home. See Kroll v. Commissioner, supra at 562. A
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