- 4 - to use of any portion of a taxpayer's home are not allowable unless the taxpayer establishes that the portion of the taxpayer's home to which the expenses relate was used exclusively and on a regular basis as the principal place of the taxpayer's trade or business. Hamacher v. Commissioner, 94 T.C. 348, 353 (1990). Occasional use of a portion of a taxpayer's home for business purposes will not satisfy the requirements of section 280A(c). Anderson v. Commissioner, T.C. Memo. 1982-576. With regard to the principal-place-of-business requirement, the Supreme Court in Commissioner v. Soliman, 506 U.S. 168, 174 (1993), explained that "principal" meant the most important or significant place for business. Whether the principal-place-of-business requirement is satisfied turns on the relative importance of the business activities performed in the home and the time spent in the home conducting these activities. Id. at 175. Petitioner argues that his various fishing activities in petitioners' basement room, shed, and garage qualify under the requirements of section 280A. We disagree. The evidence does not establish that petitioner's use of the basement room, the shed, and the garage separately or together qualifies as the principal place of petitioner's fishing business.Page: Previous 1 2 3 4 5 Next
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