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engaged in at another location. The Supreme Court has explained
as follows:
If the nature of the business requires that its services are
rendered or its goods are delivered at a facility with
unique or special characteristics, this is a further and
weighty consideration in finding that it is the delivery
point or facility, not the taxpayer's residence, where the
most important functions of the business are undertaken.
Id. at 176.
In petitioner's situation, none of his services were
performed at home. His services were all performed at the three
business locations of his principal. He received orders at those
locations to perform services at one or two of the other
businesses of his principal. To be sure, petitioner occasionally
received orders at home. On this record, it is evident that the
most important parts of petitioner's activities were performed
away from his home at the business locations of his client.
Section 280A(c)(1), with respect to tax years beginning after
December 31, 1998, provides, in pertinent part:
For purposes of subparagraph (A), the term "principal place
of business" includes a place of business which is used by
the taxpayer for the administrative or management activities
of any trade or business of the taxpayer if there is no
other fixed location of such trade or business where the
taxpayer conducts substantial administrative or management
activities of such trade or business.
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Last modified: May 25, 2011