John A. and Margaret R. Gosling - Page 7

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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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