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residence; and (2) of traveling, including lodging, from the
former residence to the new place of residence. Sec. 217(b)(1).
A. Cost of Moving Household Goods From Zurich to Saigans
For purposes of section 217, “former residence” refers to
the taxpayer’s principal residence before his departure for his
new principal place of work. Sec. 1.217-2(b)(8), Income Tax
Regs. Principal residence does not include other residences
owned or maintained by the taxpayer or members of the taxpayer’s
family. Id. Whether property is used by the taxpayer as his
principal residence depends upon all the facts and circumstances
in each case. Id.
Before his June 1999 move to Berkeley, petitioner lived in
New York City. Petitioner had lived and worked in New York City
since completing his Ph.D. degree in 1997. Additionally,
petitioner’s employment at Columbia University was not a
temporary position. On the basis of the record, we find that
petitioner’s former residence before his move to Berkeley was New
York City, not Zurich. Therefore, we hold that petitioner is not
entitled to deduct the cost of moving any household goods from
Zurich to Saigans. See sec. 217(b)(1)(A).
B. Petitioner’s Cost of Traveling From Zurich to San
Francisco
The travel cost from the former residence to the new place
of residence is a deductible moving expense. See sec.
217(b)(1)(B).
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