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.
Contrary to the Walker decision, revenue ruling 94-47 holds that a taxpayer's residence will be considered a business location for purposes of revenue ruling 90-23 only if the residence satisfies the principal place of business
requirements of section 280A(c)(1)(A).
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.
If a taxpayer's residence is his or her principal place of business
under section 280A(c)(1)(A), he or she may deduct daily transportation expenses incurred 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.
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
Since the relative importance of the work done at each location is essentially equal, the IRS applies the "time" test and decides his home office is the principal place of business
94-24 to the Soliman decision by stating examples and conclusions on whether one's home would qualify as a principal place of business
The home office must be the principal place of business
a)Ptm consultants ltd having ceased to trade having its registered office & principal place of business
at 14 castlegrange drive, clondalkin, Dublin 22 d22rc61 & (b) Macross ltd having ceased to trade having its registered office & principal place of business
at unit 26j building 65OO, cork airport business park, cork & (c)The international association of broadcast meteorology having ceased to trade having its registered office & principal place of business
at c/o Gerald fleming, 30 parkview, Wexford y35y2v3 & (d) Secure office solutions ltd never having traded having its registered office & principal place of business
at westward house, Russell street, Dublin 1, co.
280A(c)(1), expenses allocable to a home office are not deductible unless that home office is "exclusively used on a regular basis" for the following qualifying business purposes: (1) a principal place of business
, (2) a place used to meet or deal with patients, clients or customers, or (3) in the case of a separate structure not attached to the taxpayer's home, in connection with the taxpayer's business.