Wayne and June Ellen Hairston - Page 13

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          living, or family expenses may be deducted, except as otherwise             
          expressly provided in the Code.  Furthermore, section 280A                  
          narrows the general deductibility rule of section 162 when                  
          deductions are claimed for the expenses of an office in the home.           
          Sec. 280A(a).                                                               
               Section 280A(a) denies deductions with respect to the use of           
          a dwelling unit used by the taxpayer as a residence during the              
          taxable year.  Section 280A(c), however, permits the deduction of           
          expenses allocable to a portion of the dwelling unit that is used           
          exclusively and on a regular basis as "the principal place of               
          business" for any trade or business of the taxpayer.  Sec.                  
          280A(c)(1)(A).  Additionally, items such as taxes and interest              
          are allowable as deductions without regard to the business use of           
          a dwelling.  Sec. 280A(b).                                                  
               We now apply these principles to the various expenses                  
          petitioners claimed on Schedule C for the taxable years in issue.           
               Mortgage Interest Deductions                                           
               On their Schedule C, petitioners' claimed deductions for               
          mortgage interest in the amounts of $6,402, $8,442, and $7,939              
          for 1988, 1989, and 1990, respectively.  Respondent concedes that           
          petitioners are entitled to deduct mortgage interest for 1988,              
          1989, and 1990, but contends that such interest is deductible on            
          Schedule A rather than on Schedule C, as claimed by petitioners.            
          See supra note 2.                                                           






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