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facility in Stockton. The supervisor’s assurances about the
temporary nature of petitioner’s assignments during 1997 were
accurate. The supervisor’s assurances that petitioner would be
reassigned to a PCC facility in or near Stockton proved to be
false. PCC was expanding by acquiring additional facilities,
and, at least partly for this reason, petitioner repeatedly was
assigned to work at PCC’s facilities in various cities other than
Stockton until 2001. Then petitioner gave up her hopes for
reassignment to Stockton, told her supervisor that she would not
be moved about any longer, and accepted a permanent position at a
PCC subsidiary’s facility in Vista, California.
Petitioner owned only one vehicle during the year in issue,
a 1993 Toyota Corolla. She commuted daily in that vehicle
between her apartment in Stockton and the job sites in Novato,
Napa, and Yuba City. During the periods that she worked in
Bakersfield and Ukiah, she lodged overnight at the residence of a
coworker during the week and returned to her apartment in
Stockton on the weekends. Although petitioner continued to live
in Stockton and seek assignment to a PCC facility in or near
Stockton, she did not work at the Stockton facility at any time
during the year in issue.
On her 1997 Federal income tax return, petitioner reported
total income of $82,085 and itemized deductions of $26,353. She
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