Roy J. and Helen Cole - Page 4

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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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