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an ongoing relationship with an employer because he or she works
on a succession of shorter projects, the taxpayer’s employment
status is not characterized as temporary for Federal income tax
purposes. See id.; see also Yeates v. Commissioner, T.C. Memo.
1988-259, affd. 873 F.2d 1159-1161 (8th Cir. 1989).
Petitioner’s relationship with Kiewit began in 1987 and
continued through the time of trial. Kiewit employed petitioner
for most of 1990, all of 1991, all of 1992, most of 1993, and
part of 1994. All of the construction projects petitioner worked
on while employed by Kiewit in the years at issue were in
Southern California. The relationship between petitioner and
Kiewit, his primary employer, was clearly a continuing one
because of the substantial length of petitioner’s continuing
employment. Thus, it cannot be said that termination of
petitioner’s employment with Kiewit could be foreseen within a
reasonably short period of time. Albert v. Commissioner, supra
at 131.
Petitioner has not established that he maintained a personal
residence in Idaho and incurred duplicate living expenses because
of the exigencies of his work. Petitioner lodged at his parents’
house when he worked in Idaho but did not have a rental agreement
or lease with his parents. According to petitioner, he
sporadically contributed money to his parents’ household for
bills and groceries, but did not have an arrangement with them to
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