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his home office. The Supreme Court held that Dr. Soliman was not
entitled to a deduction for home office expenses because his home
office was not his "principal place of business". After
discussing various tests for determining a taxpayer's principal
place of business, the Supreme Court concluded that when a
taxpayer carries on business activities at more than one
location, the principal place of such business is the location
where the most important or significant events take place. In
Dr. Soliman's case, the most important or significant event in
the anesthesiologist's practice was the treatment of patients,
which took place at the hospitals, not at Dr. Soliman's home
office. The Supreme Court, recognizing that "in integrated
transactions, all steps are essential", nevertheless concluded
that the activities that Dr. Soliman performed at home were less
important to his medical practice than the treatments he provided
at the medical facilities. Commissioner v. Soliman, supra at
176.
Although petitioners agree that Soliman applies to their
situation, they argue that its application would result in the
allowance of the home office deduction here in dispute.
Petitioners take the position that petitioner's medical practice
should be considered as two equally important but separate
activities, one consisting of treating patients, and the other
consisting of billing and collecting from such patients.
Petitioners assert that the "principal place of business"
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