Cite as: 506 U. S. 168 (1993)
Thomas, J., concurring in judgment
I certainly agree that the word "principal" connotes " 'most important,' " ante, at 174, but I do not agree that this definition requires courts in every case to resort to a totality-of-the-circumstances analysis when determining whether the taxpayer is entitled to a home office deduction under § 280A(c)(1)(A). Rather, I think it is logical to assume that the single location where the taxpayer's business income is generated—i. e., where he provides goods or services to clients or customers—will be his principal place of business. This focal point standard was first enunciated in Baie v. Commissioner, 74 T. C. 105 (1980),1 and has been consistently applied by the Tax Court (until the present case) in determining whether a taxpayer's home office is his principal place of business.
Indeed, if one were to glance quickly through the Court's opinion today, one might think the Court was in fact adopting the focal point test. At two points in its opinion the Court hails the usefulness of the focal point inquiry: It states that the place where goods are delivered or services rendered must be given "great weight in determining the place where the most important functions are performed," ante, at 175, and that "the point where services are rendered or goods delivered is a principal consideration in most cases," ante, at 176. In fact, the Court's discomfort with the focal point test seems to rest on two fallacies—or perhaps one fallacy and a terminological obstinacy. First, the Court rejects the focal point test because "no one test is determinative in every case."
1 In Baie, the taxpayer operated a hot dog stand. She prepared all the food in the kitchen at her home and transferred it daily to the stand for sale. She also used another room in her house exclusively for the stand's bookkeeping. The Tax Court denied the taxpayer a home office deduction under § 280A(c)(1)(A), recognizing that although "preliminary preparation may have been beneficial to the efficient operation of petitioner's business, both the final packaging for consumption and sales occurred on the premises of the [hot dog stand]." 74 T. C., at 109-110. Thus, the court concluded that the hot dog stand was the "focal point of [the taxpayer's] activities." Id., at 109.
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