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Peurifoy v. Commissioner, 358 U.S. 59, 60 (1958). Under this
exception, a taxpayer’s “tax home” becomes the vicinity of the
taxpayer’s primary personal residence in a “real and substantial
sense”. Id.; see Deamer v. Commissioner, T.C. Memo. 1984-63,
affd. 752 F.2d 337 (8th Cir. 1985); Rohr v. Commissioner, T.C.
Memo. 1982-117. Employment is considered temporary only if its
termination can be foreseen within a reasonably short period of
time, but such temporary employment may become indefinite if it
is expected to last for a substantial, an indefinite, or an
indeterminate duration, or due to changed circumstances or the
passage of time. Norwood v. Commissioner, 66 T.C. 467, 469-470
(1976); Kroll v. Commissioner, supra at 562. Whether a job is
temporary or indefinite depends on the facts and circumstances of
each case. Peurifoy v. Commissioner, supra at 60-61.
The purpose of the deduction for “away from home” expenses
is “to mitigate the burden of the taxpayer who, because of the
exigencies of his trade or business, must maintain two places of
abode and thereby incur additional and duplicate living
expenses.” Kroll v. Commissioner, surpa at 562. An obvious
precondition to a taxpayer’s being away from home is that the
taxpayer have a home. See Bochner v. Commissioner, 67 T.C. 824,
828 (1977). This means that the taxpayer must have incurred
substantial continuing living expenses at a permanent place of
residence and must also have paid the expenses incurred in
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