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an office located within a taxpayer's dwelling unit is a
taxpayer's principal place of business: (1) The relative
importance of the activities performed at each business location,
and (2) the time spent at each place. Id. at 175.
We find that the importance of, and the time spent on, the
activities performed at the office are sufficient to support its
treatment as petitioner's principal place of business as manager
of the band. In addition to the various managerial and
administrative activities conducted at the office, the band
recorded and edited its promotional video and audio tapes in the
studio. The office computers and other equipment were also used
to both create and mix portions of the band's songs. We are
further persuaded by the fact that petitioner spent an average of
30 hours per week working in the home office.
Petitioner's role as the band's manager and the importance
and extent of her time spent on activities performed in the
office convinces us that her home office constitutes her primary
place of business as the band manager. Accordingly, we hold that
petitioner is entitled to the deductions claimed by her as her
share of the rent and utilities attributable to her home office.
Car and Truck Expenses
Petitioner claimed a deduction in the amount of $3,627.20
for expenses paid for transporting the band's equipment and
members from the home office to their various performance
locations. Since we have found, supra, that petitioner's home
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