John A. and Margaret R. Gosling - Page 6

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          280A(a) shall not apply to any item to the extent that such item             
          is allocable to a portion of the dwelling unit which is                      
          exclusively used on a regular basis as the principal place of                
          business for any trade or business of the taxpayer.  See sec.                
          280A(c)(1)(A).  Petitioners are therefore entitled to the home               
          office deduction only if the home office was exclusively used on             
          a regular basis as the principal place of petitioner's business.             
               Similarly, petitioners' entitlement to the car and truck                
          expense is also dependent upon petitioner's home office's meeting            
          the requirements of section 280A(c)(1)(A).  The commuting expense            
          from a taxpayer's home to his regular place of business is                   
          generally a nondeductible expense.  See sec. 1.162-2(e), Income              
          Tax Regs.  By contrast, expense of travel between a taxpayer's               
          home office and another place of business is not commuting                   
          expense and is deductible under section 162(a), if the home                  
          office is the taxpayer's principal place of business within the              
          meaning of section 280A(c)(1)(A).  See Curphey v. Commissioner,              
          73 T.C. 766, 777-778 (1980).                                                 
               We have found 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            

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