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The principal place of petitioner's timber farm, which we
have found constituted a trade or business, obviously was
located in Oregon. The principal place of petitioners'
consulting business would appear to be at the nearby southern
California offices of ALS, petitioner's former corporation and
his only client in his consulting business.
The evidence in the record does not enable us to find that
the principal place of petitioner’s computer and real estate
rental businesses was located in a portion of petitioners'
residence.
We acknowledge petitioners' extensive business and
investment activities. The evidence in this case, however, on
this issue on which petitioners have the burden of proof does
not provide us with adequate information to make an affirmative
finding that petitioners' residence constituted the primary
place of petitioner's consulting or computer and real estate
rental businesses. Commissioner v. Soliman, 506 U.S. 168, 176-
179 (1993).
We emphasize that, under section 280A, the absence outside
the taxpayer's residence of any suitable office or place in
which the taxpayer may manage investments is not adequate.
Managing investments in one's personal residence does not
qualify the residence, or any portion thereof, as a home office.
An existing trade or business must be domiciled in the
residence.
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