You are doing research exercises with a fellow student when he comes over to you with what he believes to be a rather startling discovery. He has found two cases decided on the same day by the same U.S. Tax Court judge, but with what appears to be directly contrary results. The cases appear to be exactly the same facts and issue, except one case involved a California taxpayer, while the other involved a New York taxpayer. The judge found for the taxpayer in the California case but for the IRS in the New York case. Is there any logical explanation for this?