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petitioner's educational expenditures are nondeductible personal
expenses under section 262.
On Schedule C of their 1989 tax return, petitioners claimed
a deduction in the amount of $255 for what they termed "home
expenses of teaching and practicing". The expenses were based on
a percentage of the square footage of petitioners' residence
where a Steinway concert grand piano, measuring more than 10 feet
in length, was located. The piano sits in an alcove in the
living room, and extends out into the living room. There is no
partition to separate the alcove from the rest of the room.
Section 280A generally disallows a deduction with respect to
the business use of a taxpayer's personal residence. Section
280A(c)(1)(A), however, provides that section 280A(a) shall not
apply if a portion of the taxpayer's personal residence is
exclusively used on a regular basis as the principal place of
business for any trade or business of the taxpayer. The
exclusive use test does not require that the portion of a room
used for business must be separated physically from the rest of
the room by a wall, partition, or other demarcation, but only
that the absence of such a physical separation is a factor for
the Court to weigh. Williams v. Commissioner, T.C. Memo. 1991-
567.
Petitioner testified that she used the piano strictly for
teaching and practicing. We are satisfied that the area where
the piano was located was used exclusively by petitioner for her
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