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principal place of employment. See Daly v. Commissioner, 72 T.C.
190 (1979); Kroll v. Commissioner, 49 T.C. 557, 561-562 (1968);
cf. Commissioner v. Flowers, 326 U.S. 812 (1946). If an
individual does not have a principal place of employment, we
generally deem the situs of the individual’s permanent residence
to be his or her tax home. See Rambo v. Commissioner, 69 T.C.
920 (1978); Dean v. Commissioner, 54 T.C. 663 (1970); Leach v.
Commissioner, 12 T.C. 20 (1949). We consider a person who has
neither a permanent residence nor a principal place of employment
to be an itinerant without a tax home. See Wirth v.
Commissioner, 61 T.C. 855, 859 (1974); Hicks v. Commissioner, 47
T.C. 71 (1966).
Petitioner had no principal place of employment. He did,
however, have a permanent residence; to wit, his personal
residence. We believe that petitioner’s tax home was the situs
of his personal residence in Freeland, where he resided with his
wife and their daughter. See Leach v. Commissioner, supra.5
Unlike the taxpayer in Henderson v. Commissioner, supra, who
5 In Leach v. Commissioner, 12 T.C. 20 (1949), we held that
the taxpayer’s tax home was the situs of his personal residence,
and we let him deduct the costs which he paid to lodge near some
of his work sites. The taxpayer had no principal place of
employment and resided in his personal residence with his wife
and child. He worked away from that residence for 49 weeks of
the year and could not move his wife and child to the area of any
of his work sites mainly because he was at each of the sites for
a short and indefinite period.
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