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the city where he spends more of his time, engages in greater
business activity, and derives a greater proportion of his
income. See Markey v. Commissioner, 490 F.2d 1249, 1255 (6th
Cir. 1974), revg. T.C. Memo. 1972-154; Puckett v. Commissioner,
56 T.C. 1092, 1097 (1971); Lagrone v. Commissioner, T.C. Memo.
1988-451, affd. without published opinion 876 F.2d 893 (5th Cir.
1989). For this purpose, the place where the taxpayer maintains
his or her permanent residence may be relevant but is not
conclusive. See Ziporyn v. Commissioner, T.C. Memo. 1997-151;
Lagrone v. Commissioner, supra.
During 1991, petitioner had two business activities--his
accounting and aviation activities in Minneapolis--that were
distant from his employment with Flagship Airlines in Nashville.
Although petitioner maintained his personal residence in
Nashville, for most of 1991, all other factors point toward
Minneapolis as his tax home. It appears that in 1991 petitioner
spent less than half his days in Nashville working for Flagship
Airlines, and the remaining time in Minneapolis working for Romer
& Co. and performing other aviation activities. More
significantly, petitioner earned only $11,226 in income from
Flagship Airlines in 1991, while earning gross income of
approximately $382,000 from Romer & Co. in Minneapolis and an
additional $102,313 from his other aviation activities based in
Minneapolis. We conclude that Minneapolis was petitioner’s tax
home.
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