Walter R. Strohmaier - Page 1
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113 T.C. No. 5
UNITED STATES TAX COURT
WALTER R. STROHMAIER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13353-97. Filed August 3, 1999.
P was an independent agent for an insurance
brokerage firm and a part-time minister. P was not
provided an office by the insurance brokerage firm; he
was not required to report to or visit the brokerage
firm office, nor did he conduct any business there. P,
as a minister, was not affiliated with any church. He
served as chaplain for a mobile home community, where
he performed religious services. Occasionally, P
delivered sermons or taught at various churches. In
neither activity did P receive or interview insurance
customers or religious patrons at his residence, nor
did he perform ministerial services there. P's
insurance activity was conducted by visiting clients at
their homes or other locations. P performed all the
preparatory work for both activities at his residence,
a rented apartment.
1. Held, although a portion of P's residence was
used exclusively and regularly in his two activities,
the residence was not his principal place of business.
Accordingly, the home office expenses are not
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