Ilya G. and Sophia K. Margolis - Page 13




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          A taxpayer's "principal place of business" is not simply an                 
          important or necessary place of business, but rather the "most              
          important, consequential, or influential" one.  Commissioner v.             
          Soliman, 506 U.S. 168, 174 (1993).                                          
               Petitioners are entitled to a deduction for a home office              
          because Mrs. Margolis' principal place of business for her                  
          activities was her home office.  Mrs. Margolis spent the majority           
          of her working time preparing designs at her home office.                   
          Preparing textile designs, the activity that Mrs. Margolis                  
          performed while at her home office, was of central importance to            
          her trade or business as a textile designer.  Mrs. Margolis'                
          principal place of business was her home office.  Further, Mrs.             
          Margolis exclusively used the bedroom she used as a home office             
          for her business activity.                                                  
               Therefore, petitioners are entitled to a deduction for a               
          home office expense.                                                        
               Petitioners claim a deduction for 33 percent of the general            
          expenses of their home based on a square footage ratio.                     
          Respondent contends that at a maximum petitioners are entitled to           
          a deduction for 22.5 percent of the general expenses of their               
          home.                                                                       
               As an initial matter, we must decide the general expenses              
          allocable to petitioners' home.  On their corrected 1992 return,            
          petitioners claimed that they incurred $13,641 in general home              
          expenses during 1992.  At trial, Mr. Margolis testified that the            
          $13,641 amount represented monthly rent of approximately $1,200.            

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