- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011