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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.
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