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allow a deduction for $200 attributable to tickets used by Mr.
Beck. The tickets used by Mr. Beck were personal expenses not
deductible by the corporation.
5. Insurance, Condominium Fees, Utilities, and
Property Taxes Paid for Residences of Mr. Beck, Michael, and/or
Michelle
Generally, a taxpayer may not deduct expenses with respect
to a dwelling unit that the taxpayer uses as a residence during a
taxable year. Sec. 280A(a). This general rule does not apply,
however, where the taxpayer uses a portion of the residence
regularly and exclusively as the taxpayer's principal place of
business. Sec. 280A(c)(1)(A). Mr. Beck asserts that, because
his residence address is the address used by Beck's Liquors for
purposes of State licensing and registration, that his residence
is the principal place of business of Beck's Liquors.
In Commissioner v. Soliman, 506 U.S. 168, 174 (1993), the
Supreme Court held that when a taxpayer carries on business in
more than one location the principal place of a taxpayer's
business is the most important or significant place of business.
This turns on two conditions: (1) The relative importance of the
activities performed at each business location, and (2) the time
spent at each place. Id. The most important activity of Beck's
Liquors is the sale of liquor. The sale take place in the store,
not in petitioner's condominium.
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