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same language. In enacting section 12(c), Congress intended that
section:
to apply where the taxpayer and such other members of the
household live together in such household * * * (except for
temporary absences due to special circumstances). The fact
that a child may be at college during the college term does
not prevent the home of the taxpayer from also constituting
the principal place of abode of the child. However, such
home will not be considered as the principal place of abode
where the child establishes a separate habitation and only
returns for periodic visits. * * * [H. Rept. 586, 82d Cong.,
1st Sess. (1951), 1951-2 C.B. 434; emphasis added.]
Manning v. Commissioner, 72 T.C. 838, 840 (1979).
In this case, for Maggie's absence to be "temporary" and for
petitioner's household to be considered the principal place of
abode for his daughter, petitioner must meet the following three
requirements: (1) The special circumstances or necessity of the
absence must be a type intended by the statute; (2) it must be
reasonable for petitioner to assume his daughter would return to
the household; and (3) petitioner must have maintained the
household in anticipation of such return. Id. at 840-841.
The record does not support a conclusion that Maggie's
absence from petitioner's home was temporary during 1999. Maggie
completed her undergraduate degree during 1999 at Richmond,
Virginia, where she lived and worked part-time for 4 years. She
chose to stay in Richmond not only to continue working part-time
but also to obtain an advanced degree. More importantly, there
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