Which factor is NOT considered when determining the tax home of a taxpayer with multiple employment locations?

The determination of a taxpayer’s tax home primarily centers on where a taxpayer performs their work-related duties most significantly and where their primary place of business lies. The total time ordinarily spent in performing duties, the degree of business activity, and the amount of income earned in different areas are all relevant factors in this evaluation.

Specifically, total time spent performing duties helps establish where the taxpayer is most engaged in their employment, which contributes to establishing their primary business location. The degree of business activity provides context about how involved the taxpayer is in business operations in each area, shaping decisions about tax home. The income generated in each location also gives insights into where the taxpayer is more effectively conducting their business, reflecting the significance of each employment site.

However, the total number of nights spent in each area does not directly contribute to determining the tax home. This metric, while it might show travel patterns, does not inherently reflect the taxpayer’s primary business location or the significance of work performed in each area. Thus, it is the least relevant factor in establishing a tax home compared to the others listed.