- 5 -
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).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011