- 7 - 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 upcomingPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011