Manuel Ayala, Jr., and Carol A. Ayala - Page 4




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               Mr. Ayala is employed by Sheehan Pipeline Construction                 
          Company (Sheehan) as a project safety coordinator, and he travels           
          from one project to another, all over the country, ensuring                 
          compliance with health and safety regulations.  When one project            
          is completed, he is usually assigned a new project immediately.             
          Projects can last anywhere from a few months to a couple of                 
          years.                                                                      
               During the years at issue, Mr. Ayala worked on several back-           
          to-back projects.  During this period, petitioners lived in a               
          travel trailer, and they traveled together from one job site to             
          the next.  In their own words, they were “gypsies”.  Although Mr.           
          Ayala was paid a per diem while working onsite, it did not                  
          completely cover the travel expenses that were actually incurred.           
               Petitioners bought their home on wheels, the travel trailer,           
          in Nevada; they registered the vehicle there out of convenience.            
          Because they moved frequently and had to receive their mail                 
          somewhere, petitioners used a mail service in Las Vegas that                
          provided them with a mailing address.  They obtained Nevada                 
          licenses, and later, when they purchased a truck, they registered           
          the truck in Nevada.                                                        
               As petitioners do not own a residence for their own use                
          aside from the travel trailer, they consider Mr. Ayala’s                    
          ancestral home in Vallejo, California, to be their “real” home.             








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