What is the test for determining whether a taxpayer's home is a tax haven for purposes of section 162(a)(2) of the Tax Code?
MultiRegion, United States of America
The following excerpt is from Cerny v. C.I.R., 2 F.3d 1156 (9th Cir. 1993):
The tax court's determination of the existence and location of a taxpayer's home for purposes of section 162(a)(2) is a determination of fact which will be overturned only if clearly erroneous. See Frank v. United States, 577 F.2d 93, 97 (9th Cir.1978).
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