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continue beyond a “short” period of time. Wills v. Commissioner,
411 F.2d 537, 541 (9th Cir. 1969), affg. 48 T.C. 308 (1967); see
also Coombs v. Commissioner, 608 F.2d 1269, 1274-1276 (9th Cir.
1979), affg. in part and revg. in part 67 T.C. 476 (1976).
Petitioner asserts that his employment was temporary because
each job he took had a definite end that he could estimate
beforehand. According to petitioner, the ability to predict the
duration of a particular job necessarily means that the job
cannot be indefinite, and therefore must be temporary.
Petitioner’s employment in California was not temporary.
Construction projects are typically, if not always, of limited
duration. Weichlein v. Commissioner, T.C. Memo. 1995-553.
However, this does not end the inquiry. This Court has
recognized that when the taxpayer has a series of jobs with one
employer, the actual duration of the employment relationship
between the taxpayer and employer should be considered when
determining whether the employment was indefinite. Norwood v.
Commissioner, 66 T.C. 467, 471 (1976). This is true
notwithstanding that the employment relationship consists of a
series of shorter assignments. Id. Where the employee is highly
regarded by the employer, as appears to be the case here, the
relationship between the two parties is a continuing one, subject
only to the availability of projects requiring the employee’s
skills. Weichlein v. Commissioner, supra. When a taxpayer has
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