REVRULRevenue Rule (IRB)
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If the residence doesn't meet the "principal place of business" requirements, RevRul 94-47 holds that the business activity at the residence is not sufficient to overcome the inherently personal nature of the residence.
The only two exceptions to the position taken in RevRul 94-47 are that a taxpayer can deduct daily transportation expenses incurred in going between the residence and a temporary work location outside the metropolitan area where the taxpayer lives and normally works.
RevRul 94-47 will have an adverse effect on many small business owners who work out of their home where either the home doesn't qualify as a home office or the business owner doesn't claim home office expenses for one reason or another.
Taxpayers who want to claim office-in-the-home expenses for their own merit or to deduct transportation expenses under the requirements of RevRul 94-47 must meet the tough rules of IRC Section 280A.
A congressional easing of the rules for deducting home office would make transportation cost deductions easier under RevRul 94-47.