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business is conducted in part in the taxpayer’s residence and in
part at another location, the following two primary factors are
considered in determining whether the home office qualifies under
section 280A(c)(1)(A) as the taxpayer’s principal place of
business: (1) The relative importance of the functions or
activities performed at each business location, and (2) the
amount of time spent at each location. See Commissioner v.
Soliman, 506 U.S. 168, 175-177 (1993).
Because he was a university professor, petitioner’s teaching
and research functions at the university were of primary
importance. Petitioner’s book writing project (which was
performed at his home) was of secondary importance. Petitioner
did not show that as a university professor he spent more time
working at home than at the university. Accordingly,
petitioner’s principal place of business as a university
professor was the university. Moreover, we believe petitioner
maintained an office in his home not for the convenience of the
university, his employer, but rather for his own convenience.
See Cadwallader v. Commissioner, T.C. Memo. 1989-356, affd. 919
F.2d 1273 (7th Cir. 1990); Mathes v. Commissioner, T.C. Memo.
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Last modified: November 10, 2007