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