- 17 - Court constituted their principal place of business for purposes of section 280A(c). Petitioners have presented no evidence regarding this issue. Accordingly, we sustain respondent's determination. Deductions for Utilities and Depreciation for 1988, 1989, and 1990 For the taxable years 1988, 1989, and 1990 petitioners claimed deductions for utilities and depreciation for their downtown office and for the portion of their residence that they used as an office. Respondent disallowed the portion of these deductions attributable to petitioners' home office. Petitioners may deduct utilities and depreciation attributable to their home office only if their home office was their principal place of business within the meaning of section 280A(c)(1)(A). This matter depends on the specific facts and circumstances of each particular case. Petitioner used the home office for preparing for counseling sessions. Petitioner did not meet with or counsel clients at the home office and, instead, used the downtown office for that purpose. Petitioner testified that he maintained his counseling books and accounting materials at the home office because the presence of these items in the downtown office would have intimidated the clients. In deciding whether petitioners are entitled to deductions for utilities and depreciation in excess of those allowed byPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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