Tax Legal Services · Primary-source case analysis

Soliman: The Supreme Court Required a Comparative Home-Office Inquiry

By Aneeta Mishra and Timothy Chan

Published May 3, 2026 · Updated October 18, 2026

Decision: Comm’r v. Soliman, 506 U.S. 168 (1993).

Commissioner v. Soliman interpreted the former home-office deduction rule by comparing the importance of activities and time spent across all business locations.

The physician performed administration at home

Dr. Nader Soliman used a dedicated home room for records, scheduling, continuing education, and other management work. He spent two to three hours a day at home and 30 to 35 hours a week treating patients across three hospitals, none of which supplied an office. The absence of a hospital office was real, but was not enough under the statutory test the Court then applied. Soliman, 506 U.S. at 170–171.

Principal required comparison among locations

The Court rejected a test focused mainly on whether home activity was essential and whether another office was available. It instead compared the relative importance of the functions performed at each location and, when necessary, the time spent at each.

Patient care made the hospitals more significant

The essence of the anesthesiology practice was treating patients in specially equipped hospitals. Those services were objectively more important than the supporting work at home, and the hours at the hospitals also substantially exceeded the home-office hours.

Congress later changed the statute

The Court denied the deduction under the former section 280A. Congress later amended the definition of principal place of business to address administrative or management activities performed at home when the taxpayer has no other fixed location for substantial such work. Current claims must apply today’s text rather than Soliman’s superseded formulation alone.

Key takeaways

• Confirm exclusive and regular business use of the home space.
• Identify every fixed location where substantial work occurs.
• Apply the current administrative-or-management rule.
• Keep records supporting square footage, expenses, functions, and time.