Reza and Connie M. Rezazadeh - Page 23

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          section 280A(c).  The substantiation of the amounts claimed is              
          also not at issue.                                                          
               As previously stated, section 162(a) allows a taxpayer to              
          deduct all the ordinary and necessary expenses paid or incurred             
          in carrying on any trade or business.  Section 280A, in general,            
          denies deductions with respect to the use of a dwelling unit that           
          is used by the taxpayer during the taxable year as a residence.             
          Section 280A(c)(1), however, allows the deduction of expenses               
          allocable to that portion of a dwelling unit that is exclusively            
          used on a regular basis as "the principal place of business" for            
          any trade or business of the taxpayer.  Sec. 280A(c)(1)(A).                 
          Furthermore, section 280A(c)(2) allows the deduction of expenses            
          allocable to the portion of the dwelling unit used on a regular             
          basis as a storage unit for the inventory of the taxpayer held              
          for use in the taxpayer's trade or business of selling products             
          at rental or wholesale, but only if the selling unit is the sole            
          fixed location of such trade or business.                                   
               Respondent determined, in the notice of deficiency, that               
          section 280A(c)(5) limits the deductibility of the amount claimed           
          for both the home office and inventory storage to the amount of             
          income earned by the activity.  Accordingly, respondent                     
          determined that, of the total of $1,602.86 claimed by petitioners           
          on their 1992 return for the home office and inventory storage              
          ($801.43 + $801.43), the deduction is limited to the $435.53                





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