- 9 -
6664(c)(1) are applicable here. We therefore decide in favor of
petitioners on this issue.
C. Conclusion
In closing, we think it appropriate to observe that we found
petitioners to be very conscientious taxpayers who take their tax
responsibilities seriously. Mr. Ayala’s testimony was
straightforward and credible. The Tax Court, however, is a court
of limited jurisdiction and lacks general equitable powers.
Commissioner v. McCoy, 484 U.S. 3, 7 (1987); Hays Corp. v.
Commissioner, 40 T.C. 436, 442-443 (1963), affd. 331 F.2d 422
(7th Cir. 1964). Consequently, our jurisdiction to grant
equitable relief is limited. Woods v. Commissioner, 92 T.C. 776,
784-787 (1989); Estate of Rosenberg v. Commissioner, 73 T.C.
1014, 1017-1018 (1980). Therefore, we must find that
petitioners’ ancestral home in Vallejo was not their tax home for
Federal tax purposes during the years in issue. Rather, their
tax home was wherever petitioners happened to be, and
consequently, they had no home from which to be away for purposes
of claiming deductions for travel expenses under section
162(a)(2).
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