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connection with his or her business while on the road. See
Brandl v. Commissioner, 513 F.2d 697, 699 (6th Cir. 1975), affg.
T.C. Memo. 1974-160; see also James v. United States, 308 F.2d
204 (9th Cir. 1962); Bochner v. Commissioner, supra. Where the
taxpayer maintains two residences for his own convenience,
however, such cost would be considered personal in nature and not
deductible. Sec. 262; Commissioner v. Flowers, supra at 474. In
the event that a taxpayer does not have a fixed personal
residence, the taxpayer is considered an “itinerant”, and the
taxpayer’s tax home follows the taxpayer to each place of
employment. See Michel v. Commissioner, 629 F.2d 1071, 1073-1074
(5th Cir. 1980), affg. T.C. Memo. 1977-345.
A. Temporary Versus Indefinite Employment
We first decide whether petitioner’s employment in Australia
was temporary or indefinite. Petitioner contends that he
intended to work in Australia only temporarily to establish
business contacts such that he could continue consulting for such
companies remotely from Colorado. In contrast, respondent
contends that petitioner’s employment in Australia was
indeterminate because petitioner anticipated staying in Australia
beyond 1 year, if he had work. We disagree with respondent.
Petitioner purchased a round-trip ticket to Australia good
for only 1 year, which he, in fact, used to return to the United
States within approximately 11 months. In addition, he entered
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