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home office. See also Chong v. Commissioner, T.C. Memo. 1996-232
(rejecting argument by medical doctor that billing and collecting
from patients constitutes a separate trade or business). Like
the anesthesiologists in Soliman and Chong, petitioner does not
see patients at his home office. Petitioner maintains separate
medical offices at which he performs the most important functions
of his medical practice. Petitioner’s home office was not the
principal place of business for his medical practice, or the
place used by patients, clients, or customers in meeting or
dealing with petitioner in the normal course of his trade or
business.
Petitioner argues that his home is the principal place of
business for his separate trade or business of making films and
writing and selling music. However, petitioner did not establish
how much time he spent or money he made on his film and music
activities. Petitioner testified that any receipts from his film
and music activities were commingled with those of his medical
practice and could not be accounted for or determined separately.
Any home-office deduction would be limited to the gross income
derived from the business use of the residence. Sec.
280A(c)(5); Tobin v. Commissioner, T.C. Memo. 1999-328.
Petitioner did not establish that the revenues from the use of
his home would exceed his claimed deductions for mortgage
interest and real estate taxes allocable to such use that were
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