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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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