Cite as: 506 U. S. 168 (1993)
Stevens, J., dissenting
tions set forth in § 280A, a deduction should be allowed for the ordinary cost of maintaining his home office.
In my judgment, the Court's contrary conclusion in this case will breed uncertainty in the law,17 frustrate a primary purpose of the statute, and unfairly penalize deserving taxpayers. Given the growing importance of home offices, the result is most unfortunate.
I respectfully dissent.
193
17 Most, if not all, of the uncertainty in cases debating the relative merits of the "focal point" test and the "facts and circumstances" test, as well as the uncertainty that today's opinion is sure to generate, would be eliminated by defining the term "place of business" to encompass only property that is owned or leased by the taxpayer or his employer.
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