Home Office Deductions: May a Taxpayer Have More Than One Principal Place of Business?

This Note argues that the Tax Court’s more liberal interpretation is correct because it more nearly reflects Congress’s intent. Part I seeks a basis for preferring one of the competing interpretations in the text of section 280A and in the section’s legislative history, but finds none. Looking, of necessity, to the purposes that Congress sought to advance with section 280A, Part II argues that those purposes do not demand a restrictive reading of “principal place of business.” Such a reading, moreover, would undermine fundamental and longstanding congressional tax policies. In the absence of a more explicit statement of congressional intent, this policy analysis provides a reasonable basis for rejecting the IRS’s definition and for concluding that home office expenses are deductible if the office in question is the principal place of any of the taxpayer’s businesses.