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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.
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