John A. and Margaret R. Gosling - Page 8

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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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