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We find that it was not, at least through April 18, 1994; it was,
at least through April 18, 1994, a minor post of duty.
We have considered a list of petitioner’s customers, and the
receipts that each generated, for the 1994 tax year and the
preceding and following years. Those customers are located all
over the country, and, even though the law firm provided over
one-half of petitioner’s receipts for the 1994 tax year, that was
not true for either the preceding or following year. We give
credit to Norman’s testimony that, in 1991, when the Duquettes
moved to Dallas, major business opportunities for petitioner
existed there. We also give credit to his testimony that, by
April 18, 1994, when the Duquettes sold the Dallas apartment,
petitioner’s Texas business was in decline. We, therefore, find
that Norman’s principal post of duty was in Dallas, Texas, during
the 1994 tax year, until April 18, 1994, when the Duquettes moved
from Dallas. Petitioner has failed to prove that, from April 18,
1994, until the end of the 1994 tax year, Norman’s major post of
duty was other than in the Washington, D.C., area.
Petitioner has convinced us that rental of the Bethesda
apartment was an economical alternative to the cost of hotels,
when Norman traveled to Washington on petitioner’s business.
Petitioner has also substantiated the fact of the Bethesda
apartment expenses by adequate records, principally canceled
checks. We are satisfied as to the business purpose associated
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