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465, 470 (1946). The rationale in allowing such a deduction is
to alleviate the burden falling upon a taxpayer whose business
requires that he or she incur duplicate living expenses. See
Tucker v. Commissioner, 55 T.C. 783, 786 (1971); Kroll v.
Commissioner, 49 T.C. 557, 562 (1968). Whether the taxpayer
satisfies the three recited conditions is purely a question of
fact. See Commissioner v. Flowers, supra at 470; see also Wills
v. Commissioner, 411 F.2d 537, 540 (9th Cir. 1969), affg. 48 T.C.
308 (1967).
For purposes of section 162(a)(2), generally a taxpayer’s
tax home is the vicinity of his principal place of business
rather than the location of his personal residence. See Mitchell
v. Commissioner, 74 T.C. 578, 581 (1980); Kroll v. Commissioner,
supra at 561-562. However, an exception to this general rule
exists 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 personal residence if the
employment at a different location is temporary; i.e., the
taxpayer's presence at the other location is considered to be
away from home, and the taxpayer may deduct the expenses
associated with traveling to and living at a temporary job site.
See Kroll v. Commissioner, supra at 562. A taxpayer's tax home
is the location of his or her employment if the employment is
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