Commissioner of Internal Revenue v. Nader E. Soliman (506 U.S. 168)
U.S. Supreme Court · decided January 12, 1993 · Supreme Court Database (Spaeth)
- Citation
- 506 U.S. 168 · 113 S. Ct. 701
- Decided
- January 12, 1993
- Term
- October Term 1992
- Vote
- 8–1
- Majority author
- Justice Kennedy
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
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)(l)(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 whether the home office was the principal place of business, we reverse. ► — I Respondent Nader E. Solimán, an anesthesiologist, practiced his profession in Maryland and Virginia during 1983, the tax year in question. Solimán spent 30 to 35 hours per week with patients, dividing that time among three hospitals. About 80 percent of the hospital time was spent at Suburban Hospital in Bethesda, Maryland. At the hospitals, Solimán administered the anesthesia, cared for patients after surgery, and treated patients for pain. None of the three hospitals provided him with an office. Solimán lived in a condominium in McLean, Virginia. His residence had a spare bedroom which he used exclusively as an office. Although he did not meet patients in the home office, Solimán spent two to three , hours per day there on a variety of tasks such as contacting patients, surgeons, and hospitals by telephone; maintaining billing records and patient logs; preparing for treatments…
Excerpt of a 17,924-character opinion. The full text and citation network load in the interactive viewer above.