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evenings and weekends; however, she had no set routine concerning
the use of the office. Pacific Bell did not require sales
managers to have a home office. However, Pacific Bell preferred
them to have a home office if it promoted time management,
enabled managers to access information to better coach the sales
representatives, and to keep on top of the volume of work. On
Schedule A, petitioner claimed a deduction for a home office of
$3,900.
Section 280A, in general, denies deductions with respect to
the use of a dwelling unit that is used by the taxpayer during
the taxable year as a residence. Section 280A(c) permits the
deduction of expenses allocable to a portion of the dwelling unit
that is exclusively used on a regular basis as "the principal
place of business" for any trade or business of the taxpayer.
Sec. 280A(c)(1)(A). Section 280A(c) further provides that, in
the case of an employee, deductions are allowable only if the use
of the dwelling is for the convenience of the employer.
Since petitioner was an employee, she must satisfy two tests
in order to qualify for the home-office deduction. She must
establish (1) that her home office was her principal place of
business, and (2) that she maintained the office for the
convenience of her employer. In deciding this case, the Court
must employ the definition of "principal place of business" as
set forth in Commissioner v. Soliman, 506 U.S. 168, 174 (1993).
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