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The term "principal place of business" means not merely an
important or necessary place of business, but the "most
important, consequential, or influential" one. Id. This inquiry
requires a consideration of the relative importance of the
activities performed at each location and the relative amount of
time spent at each location. Id. at 175.
On this record, we conclude that petitioner's home office
was not her principal place of business. Rather, we conclude
that petitioner performed the bulk of her work-related activities
at her downtown office. In addition, petitioner performed
substantial work at satellite offices and at offices of
customers. Accordingly, we conclude that petitioner's home
office was not her principal place of business. Petitioner,
therefore, is not entitled to a home-office deduction under
section 280A.
Accuracy-Related Penalty
Respondent determined that petitioner was liable for the
accuracy-related penalty under section 6662(a).
Petitioner's return was prepared by John D. Stoller, a
certified public accountant. Petitioner gave Mr. Stoller the
receipts for the camera, telephone, and computer and printer.
Petitioner also gave him receipts and canceled checks related to
the home-office deduction and her parking expenses. She
explained to him the circumstances related to parking at the
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