-15-
or business. Commissioner v. Flowers, 326 U.S. at 470. The
issue of the location of petitioner’s tax home is not new matter
under Rule 142(a).
Moreover, regardless of who bears the burden of proof, the
record establishes that petitioner’s tax home for the years at
issue was in Alexandria. Beginning in 1995, petitioner worked
exclusively for IDA on a series of specialized projects that
frequently required petitioner to work with classified
information accessible only in the Washington, D.C., metropolitan
area. IDA provided petitioner with work space and support staff
in Alexandria throughout the entire working relationship. Most
of the time petitioner conducted his activities for IDA in
Alexandria. Often he could only perform his services in
Alexandria, e.g., when he needed access to classified
information. Although petitioner performed some of his work for
IDA from his home in Lancaster, he could access nonsecure
information only through his connection to IDA’s computer
network. The record is devoid of any evidence that business
exigencies ever required him to perform any of his services for
IDA in Lancaster. Petitioner worked for IDA for 16 years and
exclusively for IDA beginning in 1995. Petitioner’s relationship
with IDA was indefinite and not temporary, and he had only
personal reasons for maintaining his residence in Lancaster.
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: March 27, 2008