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respondent, we must apply the definition of "principal place of
business" set forth in Commissioner v. Soliman, 506 U.S. 168,
, 113 S.Ct. 701, 706 (1993). In Soliman, the Supreme Court
emphasized two primary considerations in deciding whether a
taxpayer may treat a home office as a principal place of
business: (1) The amount of time spent at each location, and (2)
the relative importance of the activities performed at each
location.
In Soliman, the taxpayer, an anesthesiologist, administered
anesthesia and treated patients at hospitals. However, he
maintained billing records, read medical journals, and prepared
presentations and treatments in his home office. The Supreme
Court held that the taxpayer was not entitled to a deduction for
home office expenses because the taxpayer's office in his home
was not his "principal place of business". In so holding, the
Court noted that the activities which the taxpayer performed at
home were less important to the taxpayer's medical practice than
the treatments he provided at the medical facilities. Id. at
___, 113 S. Ct. at 708. The Court stated that "The actual
treatment was the essence of the professional service * * *.
* * * [and] the actual treatment was the most significant event
in the professional transaction." Id.
In analyzing the first factor set forth in Soliman, the
relative importance of the activities undertaken at each business
location, we should consider whether the functions performed in
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