No question that his employers never reimbursed Sunderam Krishnan, 2019 T. C. Sum. Op. 14, filed 7/10/19, for any “…relocation, rent, meals, telephone, internet, equipment, traveling, or commuting costs while he was working on contract projects for its clients.” 2019 T. C. Sum. Op. 14, at p. 4.

And Sun certainly worked in different places.

But his contacts with his uncle’s home in Santone were too tenuous to make it home, so STJ Panuthos finds Sun’s tax home was wherever he might be.

And Sun’s recordkeeping didn’t even come up to shoebox standards.

Sun’s bank records are sufficient, though, to get him cellphone and internet, as what he claims for business was far less than his total bills. And the 2009 liberation of cell and internet from the Section 274 straitjacket definitely helps.

Sun is an IT expert. Too bad he didn’t have the usual software to set up his records.