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taxpayer. Id. In Paguio v. Commissioner, T.C. Memo. 1981-2, the
cost of transporting the taxpayer’s two children from the
Philippines to the United States was not a deductible moving
expense under section 217(a) because before their move the two
children did not share the taxpayer’s former residence in the
United States as their principal place of abode.
Mrs. Bartsch lived in Zurich when petitioner moved to New
York City in 1997. Mrs. Bartsch continued to live and attend
school in Zurich until petitioner moved to Berkeley in June 1999.
Although Mrs. Bartsch visited petitioner while he lived in New
York City, she did not make petitioner’s residence in New York
City her principal place of abode before petitioner’s move to
Berkeley. Therefore, petitioner is not entitled to a moving
expense deduction under section 217(a) for Mrs. Bartsch’s travel
cost from Zurich to San Francisco.
D. Storage Costs
Expenses of moving household goods and personal effects
include the costs of in-transit storage. Sec. 1.217-2(b)(3),
Income Tax Regs. Storage expenses are in-transit if they are
incurred within any consecutive 30-day period after the day such
goods are moved from the taxpayer’s former residence and prior to
delivery at the taxpayer’s new residence. Id.
The storage cost in Saigans was not incurred within the
applicable 30-day period. See id. Additionally, the storage
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