Location
(iii) Location. For purposes of this paragraph (c)(2) (A) The term location means, with respect to any business and rental operations, a fixed place of business at which such operations are regularly conducted; (B) Business and rental operations are conducted at the same location if they are conducted in the same physical structure or within close proximity of one another; (C) Business and rental operations that are not conducted at a fixed place of business or that are conducted on the customer's premises shall be treated as operations that are conducted at the location (other than the customer's premises) with which they are most closely associated; (D) All the facts and circumstances (including, in particular, the factors listed in paragraph (c)(3) of this section) are taken into account in determining the location with which business and rental operations are most closely associated; and (E) Oil and gas operations that are conducted for the development of a common reservoir are conducted within close proximity of one another. (iv) Income-producing operations. For purposes of this paragraph (c)(2), the term income-producing operations means business and rental operations that are conducted at a location and relate to (or are conducted in reasonable anticipation of) (A) The production of property at such location; (B) The sale of property to customers at such location; (C) The performance of services for customers at such location; (D) Transactions in which customers take physical possession at such location of property that is made available for their use; or (E) Any other transactions that involve the presence of customers at such location. (v) Ownership by the same person. For purposes of this paragraph (c)(2), business and rental operations are owned by the same person if and only if one person (within the meaning of section 7701(a)(1)) is the direct owner of such operations. (3) Facts and circumstances determinations. In determining whether a location is the location with which business and rental operations are most closely associated for purposes of paragraph (c)(2)(iii)(D) of this section, the following relationships between operations that are conducted at such location and other operations are generally the most significant: (i) The extent to which other persons conduct similar operations at one location; (ii) Whether such operations are treated as a unit in the primary accounting records reflecting the results of such operations; (iii) The extent to which other persons treat similar operations as a unit in the primary accounting records reflecting the results of such similar operations; (iv) The extent to which such operations involve products or services that are commonly provided together; (v) The extent to which such operations serve the same customers; (vi) The extent to which the same personnel, facilities, or equipment are used to conduct such operations; (vii) The extent to which such operations are conducted in coordination with or reliance upon each other; (viii) The extent to which the conduct of any such operations is incidental to the conduct of the remainder of such operations; (ix) The extent to which such operations depend on each other for their economic success; and (x) Whether such operations are conducted under the same trade name. (4) Examples. The following examples illustrate the application of this paragraph (c). In each example that does not state otherwise, the taxpayer is an individual and the facts, analysis, and conclusion relate to a single taxable year.