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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.
We think that the importance of the activities performed at
petitioner's home office and the amount of time spent on such
activities support the conclusion that petitioner's home office
was his principal place of business. In so concluding, we rely
heavily on the fact that petitioner was not only a conductor but
rendered services in a number of other capacities. In those
other capacities, petitioner's most important functions were
performed at his home office. Cf. Genck v. Commissioner, T.C.
Memo. 1998-105.
Petitioner's role as an organizer dictated that he actually
perform, rather than merely prepare for, a substantial amount of
his important duties at the home office. From his home office,
essentially his center of operations, he carried out his
managerial and administrative duties. It was there that he
coordinated almost every logistical aspect of an upcoming
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