The Court stated that the determination of the principal place of business
depends on the facts of each particular case, but that two primary factors should be considered in making the determination: the relative importance of the activities performed at each location and the time spent at each place.
In reaction to the Supreme Court's decision in Soliman, as part of the Taxpayer Relief Act of 1997 (TRA '97), Congress passed legislation redefining a taxpayer's principal place of business
Example 3: A self-employed CPA in Scottsdale, Arizona has a qualifying office in his home, which is his principal place of business
Supreme Court narrowly construed the principal place of business
definition in a landmark case, Commissioner v.
280A(c)(1), which requires only that the office itself be used exclusively on a regular basis as the principal place of business
(in contrast to additional use for other purposes, such as personal activities); see Prop.
While Walker's residence was not established as his principal place of business
under the home-office deduction standards, it was established as his regular place of business under the language of revenue ruling 90-23.
or to deliver goods or services to a customer, the place where that contact occurs is often an important indicator of the principal place of business
280A (that is, principal place of business
used exclusively for business), there is no business use for purposes of the gain deferral.
537 ), the Tax Court allowed a self-employed tree cutter to deduct daily transportation expenses between his residence and numerous temporary work sites, even though Walker's home did not qualify as a principal place of business
If a taxpayer's residence is the taxpayer's principal place of business
within the meaning of [section]280A(c)(1)(A), the taxpayer may deduct daily transportation expenses incurred in going between the residence and another work location in the same trade or business, regardless of whether the other work location is regular or temporary and regardless of the distance.
This test will be applied only if the initial relative-importance test does not determine the taxpayer's principal place of business
a)DJ mullins engineering ltd having ceased to trade, having its registered office at 49 the fairways, Dublin road, Carlow r93k2y1 & having its principal place of business
at 49 the fairways, Dublin road, Carlow r93k2y1 & (b)Tec ined services ltd having ceased to trade having its registered office at 85 mount prospect avenue, Clontarf, Dublin 3 d03cy65 & having its principal place of business
at 85 mount prospect avenue, Clontarf, Dublin 3 d03cy65 & (c)Emo consultancy ltd trading as mary mc dermott accountant having ceased to trade, having its registered office at morette, emo, co.