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performed at each location. See Commissioner v. Soliman, 506
U.S. 168, 174 (1993).
Petitioner first contends that the Victorville home was his
personal residence and that the Thousand Oaks home was his place
of business away from home. Thus, petitioner maintains that he
is entitled to expenses for rent, repairs and maintenance,
utilities, and telephone associated with the Thousand Oaks home.
Petitioner’s contention is not supported by the evidence.
The record is clear that the Thousand Oaks home, rather than
the Victorville home, was petitioner’s personal residence and tax
home for 1998 and 1999. Petitioner testified that he kept the
Victorville home for financial reasons and that he had to rent
business property in Thousand Oaks because he could not commute
every day between Victorville and Thousand Oaks. We are unable
to accept petitioner’s testimony at face value. See Tokarski v.
Commissioner, supra at 74. We find that petitioner’s reason for
relocating to Thousand Oaks, for renting a personal residence in
Thousand Oaks, and for keeping the Victorville home was purely
personal in nature. Petitioner voluntarily relocated to Thousand
Oaks to seek gainful employment. Indeed, petitioner began
working full time at a new job with Cardservice in Thousand Oaks
and found a residence close to it. Thus, we are not convinced
that petitioner’s desire to continue working as a part-time real
estate agent established a business purpose for renting the
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