- 11 - been a proximate, rather than remote or incidental, relationship between the claimed expense and petitioner's business. Id. We have also recognized that some expenditures are so "inherently personal" that they are never deductible, regardless of the relative importance of the expenditures in connection with the taxpayer's trade or business. Fred W. Amend Co. v. Commissioner, 55 T.C. 320, 325-326 (1970), affd. 454 F.2d 399 (7th Cir. 1971). As we noted in Bakewell v. Commissioner, 23 T.C. 803, 805 (1955), where we held that the taxpayer could not deduct the cost of a hearing aid: We believe that a hearing aid is so personal as to come within the meaning of section 24(a)(1). Even if it is used in petitioner's business, * * * the device is so personal as to preclude it from being a business expense. A businessman's suit, a saleslady's dress, the accountant's glasses are necessary for their businesses but the necessity does not overcome the personal nature of these items and make them a deductible expense. * * * In this case, petitioner suggests that his status as a writer of fiction can convert otherwise personal expenses into deductible business expenses, simply because the expenditure is related to something petitioner may wish to write about. We shall address separately each category of claimed expenses. (A) Home Office Deductions Petitioner describes his entire five-room modular home as a "business location", and claims deductions for all expenses relating to rent, utilities, maintenance, furnishings, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011