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determination should be made on an activity-by-activity basis,
rather than on the basis of an integrated business. Petitioners
contend that petitioner's home office was the only place where he
conducted his billing activities. According to petitioners, the
most significant or important events in the billing process took
place at petitioner's home office; therefore under Soliman, and
pursuant to section 280A(c)(1)(A), they are entitled to treat the
home office as the principal place of petitioner's billing
"business" and are entitled to the deduction in dispute.
We disagree with petitioners' contention as to how Soliman
applies to their case. We also reject their suggestion that
section 280A(c)(1)(A), and the test established by the Supreme
Court in Soliman, should be applied on a bifurcated basis.
Petitioner's medical practice constituted a single trade or
business, albeit composed of various activities contributing to
the income earned from that trade or business. Because
petitioner's medical practice constituted a single trade or
business, it can have no more than one principal place of
business.
After taking into account petitioner's opinion with respect
to the relative importance of the various aspects of his medical
practice, and applying the "significant activity" test
established in Soliman to that practice, we find that the most
important or significant activity took place at the hospital
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