Stephan Bartsch and Eva Bartsch, a.k.a. Eva Pott Bartsch - Page 10

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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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