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and treated patients for pain at the hospitals. See id. at 170.
None of the three hospitals provided the taxpayer with an office.
See id.
The taxpayer had a spare bedroom in his residence which he
used exclusively as an office. See id. The taxpayer did not
meet with patients at his home office, but he did spend 2 to 3
hours per day there performing various administrative tasks, such
as: (1) Contacting patients, surgeons, and hospitals by
telephone, (2) maintaining billing records and patient logs, (3)
preparing for treatments and presentations, (4) satisfying
continuing medical education requirements, and (5) reading
medical journals and books. See id. On the basis of these
circumstances, the Supreme Court held that the home office was
not the taxpayer's principal place of business, and therefore the
taxpayer was not entitled to a deduction for home office
expenses. See id. at 178-179.
In the instant case, petitioner's services are not performed
at the home office. Instead, his floor covering services are
performed at the job sites. Therefore, while the home office was
an important place for petitioner's business, we cannot say that
it was his principal place of business. Accordingly, petitioner
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