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concert. He also performed his duties as Hilton Head's
impresario from that location. Finally, he performed part of his
duties as a conductor, e.g., selecting the repertoire, at his
home office. His home office was therefore the point of delivery
of a substantial portion of his services.
Also important is the fact that petitioner spent the
majority of his working hours at his home office. This factor
bolsters the conclusion that petitioner's home office was not
just an ancillary place of business, but rather the principal
place of his business.
Having considered the importance of the activities performed
at petitioner's home office and the amount of time spent on such
activities, we are convinced that petitioner's principal place of
business was his home office.
In light of the foregoing, we hold that petitioners are
entitled to the deductions for home office and car and truck
expenses at issue herein.
To reflect our disposition of the disputed issue, as well as
petitioners' concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011