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indefinite or permanent; i.e., the taxpayer's presence at a
second location is not considered away from home. See id.
A place of business is a temporary place of business if the
employment is such that termination within a short period of time
can be foreseen. See Albert v. Commissioner, 13 T.C. 129, 131
(1949). Conversely, employment is categorized as indefinite,
substantial, or indeterminate if its termination cannot be
foreseen within a fixed or reasonably short period of time. See
Stricker v. Commissioner, 54 T.C. 355, 361 (1970), affd. 438
F.2d. 1216 (6th Cir. 1971). Employment which is temporary may
become indefinite due to changed circumstances or the passage of
time. See Norwood v. Commissioner, 66 T.C. 467, 470 (1976).
When that occurs, the location of the taxpayer's employment
becomes his or her tax home. See Kroll v. Commissioner, supra at
562. Whether a taxpayer’s employment is temporary or indefinite
is a question of fact. See Peurifoy v. Commissioner, supra at
61; cf. Harvey v. Commissioner, 283 F.2d 491 (9th Cir. 1960),
revg. 32 T.C. 1368 (1959). However, a "taxpayer shall not be
treated as being temporarily away from home during any period of
employment if such period exceeds 1 year." Sec. 162(a).
Petitioners contend that, even though petitioner’s
employment in Los Angeles eventually lasted several years, it was
temporary during 1994 because, at that time, it could not have
reasonably been foreseen, nor was it intended by the parties,
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