The Tax Court in Johnson 115 TC 210 lays out the concept of tax home. Citations omitted.
We disagree with respondent's assertion that petitioner had no tax home. This Court's jurisprudence holds that an individual's tax home is generally the location of his or her principal place of employment. .... If an individual does not have a principal place of employment, we generally deem the situs of the individual's permanent residence to be his or her tax home. ....We consider a person who has neither a permanent residence nor a principal place of employment to be an itinerant without a tax home.
We disagree with respondent's assertion that petitioner had no tax home. This Court's jurisprudence holds that an individual's tax home is generally the location of his or her principal place of employment. .... If an individual does not have a principal place of employment, we generally deem the situs of the individual's permanent residence to be his or her tax home. ....We consider a person who has neither a permanent residence nor a principal place of employment to be an itinerant without a tax home.
Comment