Christopher D. and Kristie M. Farran - Page 9

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               All the facts and circumstances are considered in                      
          determining whether a taxpayer has a tax home.  See Rev. Rul. 73-           
          529, 1973-2 C.B. 37 (describing objective factors the                       
          Commissioner considers in determining whether a taxpayer has a              
          tax home).  The taxpayer must generally have some business                  
          justification to maintain the first residence, beyond purely                
          personal reasons, to be entitled to deduct expenses incurred                
          while temporarily away from that home.  Hantzis v. Commissioner,            
          638 F.2d 248, 255 (1st Cir. 1981); Bochner v. Commissioner, 67              
          T.C. 824, 828 (1977); Tucker v. Commissioner, 55 T.C. 783, 787              
          (1971).  Where a taxpayer has no business connections with the              
          area of primary residence, there is no compelling reason to                 
          maintain that residence and incur substantial, continuous, and              
          duplicative expenses elsewhere.  See Henderson v. Commissioner,             
          143 F.3d 497, 499 (9th Cir. 1998), affg. T.C. Memo. 1995-559;               
          Deamer v. Commissioner, supra; Hantzis v. Commissioner, supra.              
          In that situation, the expenses incurred while temporarily away             
          from that residence are not deductible.  Hantzis v. Commissioner,           
          supra; Bochner v. Commissioner, supra; Tucker v. Commissioner,              
          supra; see McNeill v. Commissioner, T.C. Memo. 2003-65; Aldea v.            
          Commmissioner, T.C. Memo. 2000-136.                                         
               Once Mr. Farran was bumped from Minneapolis, he had no job             
          to return to there.  His choices were to be laid off and have no            
          work, or to bump other employees and move to different cities to            

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