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taxpayer". Thus, to qualify under section 280A(c) for a home
office deduction, petitioner must establish that a portion of his
dwelling is (1) exclusively used, (2) on a regular basis, and (3)
as the principal place of business for his trade or business.
See Hamacher v. Commissioner, 94 T.C. 348, 353 (1990).
We are satisfied that petitioner's home office was used
exclusively and regularly in petitioner's business. We now
consider whether petitioner's home office was his principal place
of business.
In Commissioner v. Soliman, 506 U.S. 168 (1993), the Supreme
Court identified two primary factors to be considered in deciding
whether a home office is the 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.
See id. at 175. The relative importance of the activities
performed at each business location is to be determined by the
basic characteristics of the taxpayer's particular business. The
point where goods and services are delivered must be given great
weight in determining the place where the most important
functions are performed. See id.
In Commissioner v. Soliman, supra, the taxpayer was an
anesthesiologist who divided the practice of his profession among
three hospitals in Maryland and Virginia. The taxpayer
administered the anesthesia, cared for patients after surgery,
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