Soliman v. Commissioner
United States Tax Court
P used a room in his apartment exclusively to manage his medical practice. He had no other office space available to him. His business activities at his home office were essential to his medical practice but were ancillary to the primary income-generating services he performed at hospitals. Held: P is entitled to deduct expenses for his home office.
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P used a room in his apartment exclusively to manage his medical practice. He had no other office space available to him. His business activities at his home office were essential to his medical practice but were ancillary to the primary income-generating services he performed at hospitals. Held: P is entitled to deduct expenses for his home office. We will no longer follow the "focal point" test of Drucker v. Commissioner, 79 T.C. 605 (1982), revd. 715 F.2d 67 (2d Cir. 1983) in cases in which a taxpayer's home office is essential to his business, he spends substantial time there, and there…
1Opinion of the Court
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioner’s 1983 Federal income tax as follows:
Sec. Sec. Sec. Sec. Deficiency 6651(a)(1)1 6653(a)(1) 6653(a)(2) 6661
1983 $20,338 $1,089 $2,538 * $3,864
*50 percent of the interest due on the underpayment.
The issues we must decide are: (1) Whether petitioner is entitled to a home office deduction pursuant to section 280A, (2) whether petitioner is entitled to a business expense deduction for the use of his automobile, (3) whether petitioner is entitled to a deduction for expenses incurred in traveling to the Virgin Islands and Orlando,…
2Cases cited13 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Sharon v. CommissionerUnited States Tax Court · 1976
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Baie v. CommissionerUnited States Tax Court · 1980
- Jackson v. CommissionerUnited States Tax Court · 1981
8 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Commissioner v. SolimanSupreme Court of the United States · 1993
- Hamacher v. CommissionerUnited States Tax Court · 1990
- Thomas C. Cadwallader and Judy C. Douglas v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1990
- Crawford v. CommissionerUnited States Tax Court · 1993
- BanatwalaUnited States Tax Court · 1992
11 more not listed; retrieve them via the Exa API.