Yeates v. Commissioner

Raymond Yeates (plaintiff) was an electrician who lived in Illinois with his wife, Donna (plaintiff), until 1975. Raymond had seniority in the International Brotherhood of Electrical Workers (IBEW) Local 134 union and regularly received assignments from Local 134 for work in Chicago. The Yeateses subsequently moved to Arkansas and then to California, where Raymond found some work through other IBEW locals. The Yeateses moved back to Arkansas in April 1981 and maintained their legal residence in Arkansas after that point. However, Raymond never worked in Arkansas. Rather, Raymond continued working in California until September 1981 and then worked in Chicago from October 1981 through 1986. During the 1983 tax year, Raymond worked in Chicago for ten-and-a-half months while his family lived in Arkansas. On the Yeateses’ 1983 federal income-tax returns, Raymond and Donna claimed a business-expense deduction of $16,156.25 for traveling and living expenses Raymond had incurred while working in Chicago. However, the Commissioner of Internal Revenue (the commissioner) (defendant) disallowed the deduction. The commissioner found that Chicago should be considered Raymond’s tax home for 1983, and therefore that Raymond’s expenses for meals, lodging, and transportation were nondeductible personal expenses. The Yeateses challenged the commissioner’s decision in tax court. After a trial, the court concluded that Chicago was Raymond’s tax home because his work there was indefinite, not temporary, given Raymond’s ability to find fairly steady work in Chicago due to his seniority in Local 134. The court thus agreed with the commissioner that Raymond’s expenses were nondeductible. The Yeateses appealed, arguing, among other things, that Raymond’s 1983 employment in Chicago was temporary because Local 134 had contracted Raymond to 10 different employers for short jobs.