Michael D. and Suzan L. Storer - Page 8




                                        - 7 -                                         
               Legal and                     265            285                       
               professional                                                           
               Office2                       0              0                         
               Rent or lease                 0              0                         
               Repairs and                   0              0                         
               maintenance                                                            
               Supplies                 1,039          1,383                          
               Taxes and                     0              0                         
               licenses                                                               
               Travel                        0              0                         
               Utilities                     0              25                        
               Other                         154            103                       
               Expenses for business       6,348          5,739                       
          use of home                                                                 
               Total expenses            $21,421        $16,050                       
               In the notice of deficiency, respondent disallowed                     
          petitioners’ claimed Schedule C deductions for expenses on the              
          ground that petitioners were not engaged in a trade or business             
          activity for profit.  However, respondent allowed as additional             
          itemized deductions real estate taxes and mortgage interest                 
          included in the computation of expenses of business use of home.            
          In addition, respondent allowed Schedule C expenses to the extent           
          of income reported from the activity.                                       
                                     Discussion                                       
               The parties disagree as to whether petitioners engaged in              
          their Schedule C activity with an objective of making a profit              
          within the meaning of section 183.  Section 183(a) disallows                


               2 On their Schedules A, Itemized Deductions, petitioners               
          claimed that 44 percent of their home was used as office space.             
          They did not, however, upon request, allow respondent’s agent               
          into their home to survey this space, claiming that such a visit            
          would be “unnecessary and unwise.”                                          





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Last modified: November 10, 2007