Your tax home is not always be where you think it is… It may not be where you live. As a self-employed consultant lived in Ga.found out. He spent his time at his client’s offices in N.J. for four days each week.
He deducted his travel to and from N.J. as business expenses on his Schedule C. He argued that, because he was a consultant with no principal place of business and could complete work at multiple locations, including the airport and his home, his tax home was in Ga., where he resided. But the Tax Court shot that down, saying his tax home was in N.J., in part because all his business income was derived from his N.J. client during the year at issue. The argument would have held up better if he had more than one client.
We had a client with a similar situation, but the state where he lived wanted to tax all of the earned income, because his tax home was in Illinois.
Brown, TC Memo. 2019-30