Roy J. and Helen Cole - Page 5

                                        - 5 -                                         

          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            

Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011