Quimbee logo
DMCA.com Protection Status
From our private database of 18,800+ case briefs...

Popov v. Commissioner

United States Court of Appeals for the Ninth Circuit
246 F.3d 1190 (2001)


Katia Popov and her husband (plaintiffs) lived with their child in a one-bedroom apartment. Popov was a professional violinist who performed with orchestras and made recordings. The recording studios offered no space and almost no time for practicing the music to be recorded. Therefore, musicians had to find their own practice spaces. Popov’s practice space was the living room of her small apartment. The living room was furnished and used solely by Popov as her practice space. Popov spent more time practicing at home than she spent performing. The Popovs deducted a portion of their apartment costs as home-office expenses. Under § 280A(c)(1)(A) of the federal tax code, home-office expenses were tax deductible only if the home office exclusively served as the taxpayer’s principal place of business. The commissioner of internal revenue (commissioner) (defendant) disallowed the deduction, determining that Popov’s principal places of business were the venues where she performed professionally, not the living room where she practiced. The Popovs petitioned the tax court for a redetermination, and the tax court ruled for the commissioner. Popov appealed.

Rule of Law


Holding and Reasoning (Hawkins, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 498,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 498,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial