Joon H. Chong and Youngcha Kim Chong - Page 5

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          consulted with patients for medical treatment purposes at his               
          home office.                                                                
               Petitioners estimated that petitioner's home office                    
          constituted approximately 27 percent of the total area of their             
          house.  On the Schedule C related to petitioner's medical                   
          practice, petitioners deducted $10,343.12 as expenses for the               
          business use of their house.  Included in this total are amounts            
          attributable to depreciation, mortgage interest, property taxes,            
          utilities, insurance, and repairs and maintenance.  Car expenses,           
          including depreciation, in the total amount of $4,615 were also             
          deducted on the Schedule C.  Petitioners estimated that the                 
          automobile to which the expenses related, a 1989 Mazda, was                 
          driven 7,000 miles in 1992.  Of the total miles driven,                     
          petitioners' return reflects that 6,300 miles were business                 
          related and 700 miles related to personal, noncommuting purposes.           
               In the notice of deficiency upon which this case is based,             
          respondent disallowed petitioners' home office deduction upon the           
          ground that the home office was not the principal place of                  
          petitioner's medical practice.2  Having determined that                     
          petitioner's house was not his principal place of business,                 
          respondent decreased petitioners' car expenses by $4,108 upon the           



          2In the notice of deficiency respondent increased                           
          petitioners' itemized deductions by the amounts of the real                 
          estate taxes and mortgage interest disallowed as part of the home           
          office deduction.  Sec. 280A(b).                                            




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