- 11 - regular basis as the taxpayer’s principal place of business. Sec. 280A(c)(1).5 Petitioners introduced pictures of their home and prepared a rough sketch of the home layout including square footage. Mr. Soholt also described the layout of his home office and explained the setup of his work area, filing cabinets, and storage space for his MetLife marketing materials. Mr. Soholt admitted that he kept a few personal documents in the filing cabinet such as wills, copies of tax returns and similar documentation, but the family living area was located on another floor of the home and the office area was not used for anything other than Mr. Soholt’s business activities. The home office constituted 18 percent of petitioners’ home based on square footage. We have carefully examined the parties’ exhibits and Mr. Soholt’s testimony on this issue. We find his testimony on this issue to be credible and the documents reliable. We conclude that 18 percent of petitioners’ home was regularly and exclusively used as the principal place of business for Mr. Soholt’s MetLife affairs. Petitioners are therefore entitled to 5There is an additional requirement that the home office be for the convenience of the employer. Sec. 280A(c)(1) (flush language). The record is unclear whether the parties dispute this issue. Unreimbursed business expenses are subject to the 2- percent limitation of sec. 67.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007