- 11 - The principal activities relating to petitioner's scrap metal recycling business consist of the collection, processing, and resale of scrap metal, the principal aspects of which are performed at petitioner's warehouse. The warehouse appears to be a facility with unique or special characteristics capable of processing and storing scrap metal. These activities are not performed in petitioner's home office. The administrative, management, and other activities performed in petitioner's home office certainly constitute a relevant part of petitioner's business, but because the scrap metal is collected and processed at the warehouse, the warehouse is to be regarded as the principal place of petitioner's scrap metal recycling business. Petitioner argues that negotiations for the purchase and sale of scrap metal that he conducts primarily over the telephone from his home office constitute the principal activity of his business. Petitioner, however, has not established in this case that the actual purchase and sale of scrap metal is to be treated as occurring in his home office, nor that negotiations for the purchase and sale of scrap metal that are conducted over the telephone from his home office constitute the principal activity of the business. Further, for expenses of a home office to qualify for deductibility under section 280A, no personal use may be made of the particular area of a residence that is used as the homePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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