- 7 -
required to report to petitioner’s home for their training, and
there is no evidence that petitioner ever trained NOAA employees
at his home.
As to the disallowed claimed deductions for insurance,
repairs and maintenance expenses, and utilities, those expenses
related to petitioner’s use of his home in connection with his
NOAA contract.
Generally, in determining whether a home constitutes the
taxpayer’s principal place of business, the Court examines the
various locations in which the activity is conducted, the
relative importance of the activities performed at each business
location, and the time spent at each place. To be sure, although
petitioner’s home was helpful and used in connection with his
NOAA contract, the evidence in this case fails to persuade the
Court that petitioner’s home was the principal place of his
business activity nor was his home exclusively used for such
activity. Rather, the Court finds that the training of the NOAA
employees was of primary importance and that the NOAA facility
was petitioner’s principal place of business. The Court,
therefore, concludes that the facts of this case do not establish
petitioner’s entitlement to deductions for home office expenses
under section 280A(c)(1). The Court sustains respondent’s
determinations.
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8
Last modified: March 27, 2008