Kevin L. and Victoria L. Hargrove, et al. - Page 10

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          employee does significant work for the employer or the employer             
          conducts a significant portion of its business at the living                
          quarters.  See Johnson v. Commissioner, supra.  For example,                
          housing located 12 miles from the employee’s worksite on the                
          trans-Alaska pipeline was not integral to the employer’s business           
          where the employee only prepared some daily inspection reports at           
          home. Id.  Also, proximity is not the standard.  Living quarters            
          as close as a mile from the worksite are not integral to the                
          employer’s business even if the employee is periodically on call            
          to perform work for the employer unless the employee performs               
          significant work for the employer at the living quarters.  See              
          Dole v. Commissioner, supra.                                                
               The homes where petitioners and their families lived in                
          Alice Springs were 22 miles from the defense facility.  The                 
          housing was in a separate town on a public road in the same areas           
          where nonbase employees lived.  No TRW activities occurred at the           
          housing petitioners occupied in Alice Springs.  No petitioner               
          performed any work for TRW at his or her home in Alice Springs.             
          Accordingly, the housing in Alice Springs was not an integral               
          part of TRW’s business and having petitioners occupy those                  
          particular homes served no important TRW business functions.                
               We conclude that the living quarters TRW provided                      
          petitioners were not integral to TRW’s business.  The living                
          quarters therefore do not qualify for the exclusion under section           
          119, and petitioners are not entitled to exclude the costs of               
          their lodging from their income for the relevant years.                     





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