- 6 -6 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, 77Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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