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two conditions: (1) the relative importance of the activities
performed at each business location, and (2) the time spent at
each place. Here we find that most of petitioner’s locksmith
work was done on the premises of customers or third parties. The
alleged home office in his garage was not petitioner’s principal
place of business. Although petitioner stored certain equipment,
machines, and some inventory of the locksmith business in his
garage, he failed to show that the office was used exclusively
for business purposes. We are aware of the exception provided in
section 280A(c)(1)(C) that if an office is a “separate structure”
not attached to the dwelling unit and is used in connection with
the taxpayer’s trade or business, a home office deduction may be
justified. However, the statute requires that the separate
structure be used exclusively for business purposes in order to
qualify for the deduction. The Senate committee report that
accompanied the legislation enacting section 280A(c)(1)(C) states
“with respect to a separate structure not attached to the
dwelling unit, if the taxpayer uses such structure (e.g., a
detached garage) for both trade or business and personal
purposes, the exclusive use test is not met”. S. Rept. 94-938,
at 148 (1976), 1976-3 C.B. (Vol. 3) 57, 186.
Here petitioner provided limited testimony regarding his use
of the garage office. While he introduced into evidence a hand
drawn sketch of the alleged office, it is not possible to
determine from the drawing whether the garage unit is a detached
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