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COMMISSIONER v. SOLIMAN

No. 91-998.

506 U.S. 168 (1993)

COMMISSIONER OF INTERNAL REVENUE v. SOLIMAN

United States Supreme Court.

Decided January 12, 1993.

Attorney(s) appearing for the Case

Kent L. Jones argued the cause for petitioner. With him on the briefs were Solicitor General Starr, Acting Assistant Attorney General Bruton, Deputy Solicitor General Wallace, Richard Farber, and Teresa E. McLaughlin.

David M. Sokolow argued the cause and filed a brief for respondent.

Kennedy, J., delivered the opinion of the Court, in which Rehnquist, C. J., and White, Blackmun, O'Connor, and Souter, JJ., joined. Blackmun, J., filed a concurring opinion, p. 179. Thomas, J., filed an opinion concurring in the judgment, in which Scalia, J., joined, p. 180. Stevens, J., filed a dissenting opinion, p. 184.

Justice Kennedy, delivered the opinion of the Court.

We address in this decision the appropriate standard for determining whether an office in the taxpayer's home qualifies as his "principal place of business" under 26 U. S. C. § 280A(c)(1)(A). Because the standard followed by the Court of Appeals for the Fourth Circuit failed to undertake a comparative analysis of the various business locations of the taxpayer in deciding...

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