Joe D. and Maura F. White - Page 10




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          Petitioner did not establish that he conducted substantial                  
          administrative or management activities of his trade or business            
          at his home.  Except for occasional telephone calls he received             
          at home with respect to some of his work assignments, there was             
          no other evidence presented that would satisfy the Court that               
          petitioner's home was the situs of management or administrative             
          activity related to his activity.                                           
               Petitioner also contended that, because he stored equipment            
          used in his business activity in a shed on his home premises,               
          such fact entitles petitioners to a home office deduction.                  
          Section 280A(c)(1) provides, in pertinent part:                             

                    (1) Certain business use.–-Subsection (a) shall not               
               apply to any item to the extent such item is allocable to a            
               portion of the dwelling unit which is exclusively used on a            
               regular basis--                                                        
          *       *       *       *       *       *       *                           
                    (C) in the case of a separate structure which is not              
               attached to the dwelling unit, in connection with the                  
               taxpayer's trade or business.                                          

          However, none of the expenses petitioners claimed with respect to           
          their home office related to the shed.  All of the claimed                  
          expenses related to the room in petitioners' home.  Petitioners,            
          therefore, are not entitled to a deduction for home office                  
          expenses.                                                                   








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