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It is presumed that a taxpayer will generally choose to live
near his or her place of employment. Frederick v. United States,
603 F.2d 1292, 1295 (8th Cir. 1979). A taxpayer must, however,
have a principal place of employment and accept temporary work in
another location to be away from home. Kroll v. Commissioner,
supra. A person who has no principal place of business nor a
place he or she resides permanently is an itinerant and has no
tax home from which he or she can be away. Deamer v.
Commissioner, 752 F.2d 337, 339 (8th Cir. 1985), affg. T.C. Memo.
1984-63; Edwards v. Commissioner, T.C. Memo. 1987-396.
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
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,
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Last modified: November 10, 2007