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exclusively or regularly for such activity, nor did these areas
constitute petitioner’s principal place of business.
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
are necessary to the business is relevant but not controlling.
The location at which goods and services are delivered to
customers generally will be regarded as an important indicator of
the principal place of the taxpayer’s business and is given great
weight in most cases. See id. at 175, 176. The relative
importance of business activities engaged in at the home may be
substantially outweighed by business activities engaged in at
another location. The Supreme Court has stated:
If the nature of the business requires that its
services are rendered or its goods are delivered at a
facility with unique or special characteristics, this
is a further and weighty consideration in finding that
it is the delivery point or facility, not the
taxpayer’s residence, where the most important
functions of the business are undertaken.
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