The taxpayer, who resided in Calgary and was enrolled in the Seattle Midwifery School, attended classes in Seattle for five days a month initially and two days a month later on, and also did online studies and practical studies in Calgary.
In finding that the taxpayer "commuted" to Seattle, Rip J. stated (at p. 1349) "if the individual is wont to travel from his or her residence to another locality hundreds of miles away on a regular or frequent basis, that person is commuting between the two places." However, she did not reside "near" to the Canada-U.S. border.