Robert Lyle Verity - Page 16

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          condominium as his “home” does not satisfy the requirements of a            
          tax home within the meaning of section 162(a)(2).                           
               On the basis of the record, petitioner was an itinerant for            
          purposes of section 162(a)(2).  Therefore, his place of residence           
          follows him to his place of employment.  See Michel v.                      
          Commissioner, 629 F.2d at 1073-1074.  Although petitioner may               
          have maintained his “business headquarters” in Colorado and had             
          all his compensation wired to his business bank account in                  
          Colorado, his principal place of employment was in Australia.               
          Indeed, all of the expenses at issue were incurred for                      
          petitioner’s consulting services performed in Australia, not in             
          Colorado.  Accordingly, we conclude that petitioner’s tax home,             
          for purposes of section 162(a)(2) for the relevant time period,             
          was Australia.  We thus sustain respondent’s determination.                 
                                     Conclusion                                       
               We have considered all of the other arguments made by                  
          petitioner, and, to the extent that we have not specifically                
          addressed them, we conclude that they are without merit.                    
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   












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