Neville Shute’s 1950 classic forms the background for Cory s/a/k/a Corey Smith, T. C. Memo. 2023-6, filed 1/12/23. Corey a/k/a Cory is also a returning customer, as Cory a/k/a Corey starred in my blogpost “Unclosed?” 8/25/22.

Corey a/k/a Cory is offered housing in Alice Springs, Northern Territory, Australia, which he takes. He’s there as a spy-in-the-sky for Raytheon, and claims his housing off-base is for the convenience of employer, and therefore excludable under Section 119.

It’s facts-and-circumstances, but the question is what work did Corey a/k/a Cory do at home. And the key-fob that let him into the Raytheon cyberloop from home to do employee evaluations, timesheets, and mandatory job training isn’t enough; you have to be on-premises by day and by night, and Alice Springs is too far from the jobsite to qualify.

We saw a variant of this play out here in The Empire State recently. A tough bar to clear.