Robert Lyle Verity - Page 11

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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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