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that petitioner's residence constituted the principal place of
business for his two activities.
Where a taxpayer's business is conducted in part in the
taxpayer's residence and in part at another location, the
following two primary factors are considered in determining
whether the home office qualifies under section 280A(c)(1)(A) as
the taxpayer's principal place of business: (1) The relative
importance of the functions or activities performed at each
business location, and (2) the amount of time spent at each
location. See Commissioner v. Soliman, 506 U.S. 168, 175-177
(1993).
Whether the functions or activities performed at the home
office are necessary to the business is relevant but not
controlling, and the location at which goods and services are
delivered to customers generally will be regarded as an important
indicator of the principal place of a taxpayer's business, which
must be given great weight and is a principal consideration in
most cases. See id. at 175, 176. The relative importance of
business activities engaged in at the home office may be
substantially outweighed by business activities engaged in at
another location. The Supreme Court has explained as follows:
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