Gary G. Bendickson - Page 7




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               Petitioner’s position is that because his principal place of           
          business was the cabin where he lived, he could deduct daily                
          transportation expenses incurred between his residence and                  
          another work location.  Respondent’s position is that the                   
          principal place of business was the office of petitioner’s                  
          father.                                                                     
               In Commissioner v. Soliman, 506 U.S. 168 (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. at 175.  Here we find that most of petitioner’s            
          accounting services were rendered on the premises of his father’s           
          office in Plymouth, Minnesota.  Petitioner went to that office              
          four times each week during the years in issue.  Petitioner met             
          with clients at his father’s Plymouth office.  Petitioner                   
          admitted that he did not meet with clients at the cabin where he            
          was living.  On his Schedules C for the 3 years, petitioner                 
          listed the Plymouth office address as his business address.                 
          Petitioner testified that his principal place of business was the           
          cabin where he resided and that he kept some records there.  We             
          are not required to accept the self-serving testimony of                    
          petitioner as gospel.  Tokarski v. Commissioner, 87 T.C. 74, 77             





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