Robert and Cheryl McKeown - Page 10

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          see McNeill v. Commissioner, T.C. Memo. 2003-65; Aldea v.                   
          Commissioner, T.C. Memo. 2000-136.                                          
               Once Mr. McKeown 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            
          continue working.  NWA no longer required Mr. McKeown to perform            
          any services whatsoever in the Minneapolis area once he was                 
          bumped.  Although Mrs. McKeown and petitioners’ daughter remained           
          in the family residence with occasional visits from Mr. McKeown             
          while he worked in Detroit, Newark, and New York, this fact alone           
          does not dictate that Mr. McKeown’s tax home was in Monticello,             
          Minnesota, where the family residence was located.  Unlike                  
          traveling salespersons who may be required to return to the home            
          city occasionally between business trips, Mr. McKeown’s business            
          ties to the Minneapolis area ceased when he was bumped.                     
               The Court understands that the NWA mechanics’ lives were               
          unsettled and disrupted.  Mechanics did not know how long they              
          would have a job in one specific location.  They only knew the              
          system was based on seniority.  They could bump less senior                 
          employees, and they could be bumped by more senior employees.               
          While we acknowledge that Mr. McKeown would have liked to return            
          to the Minneapolis area to work for NWA, Mr. McKeown did not know           
          when such a return would be possible due to the seniority system.           
          The likelihood of Mr. McKeown’s return to a position in                     

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