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statements post the locations where he withdrew money or
purchased items.
On the basis of the record, the Court finds that petitioner
did not have a tax home in 2000. Petitioner traveled nationwide
and had no principal place of employment. While petitioner may
have believed that Sacramento was his home and made an effort to
return whenever possible, that belief is not sufficient to
establish Sacramento as his tax home.
Petitioner did not have a legal or equitable interest in the
condo. The letters dated 2002 show that petitioner was obligated
to pay rent to the Tiernans. But, it is unclear what
petitioner’s monthly rent was in 2000 or how much rent was
actually paid during that year. The check register shows that
petitioner paid to Mrs. Tiernan $2,000 by check No. 2057 dated
May 30, 2000, “for Condo”. There are no other entries in the
check register that relate directly to a payment on the condo.
The record shows that petitioner traveled 268 days out of the
year or 73.42 percent. Petitioner’s financial contribution of
$2,000 for the condo is minimal when compared to the $21,866.57
of living expenses that he incurred while traveling. See
Henderson v. Commissioner, supra.
Petitioner asserts that he returned to his condo after each
job because that was his “base” and that he, for the most part,
spent time in Sacramento between jobs. The bank statements,
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