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“carried his home on his back”, to have been an itinerant, and is
not entitled to the deduction because he was not “away from
home”. Wirth v. Commissioner, 61 T.C. 855, 859 (1974); Hicks v.
Commissioner, 47 T.C. 71, 74 (1966). The purpose of the “away
from home” provision is to mitigate the burden of the taxpayer
who, because of exigencies of his trade or business, must
maintain two places of abode and thereby incur additional and
duplicate living expenses. Kroll v. Commissioner, 49 T.C. 557,
561-562 (1968); Hicks v. Commissioner, supra. A taxpayer has a
“home” when he has incurred substantial continuing living
expenses at a permanent place of residence. James v. United
States, 308 F.2d 204, 208 (9th Cir. 1962); Wirth v. Commissioner,
supra.
Respondent argues that petitioner may not deduct the cost of
travel, meals, and lodging that petitioner paid during 2000,
because petitioner had no tax home.
Petitioner argues that in 2000, his tax home was in
Sacramento, California. Petitioner asserts that he owns the
condo, paid the utilities, returned to the condo between jobs,
and used the condo’s address to report his Federal taxes. In
support, petitioner presented utility bills and bank statements.
Petitioner contends that the bank statements show that he was in
Sacramento during his periods of unemployment in 2000, since the
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