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insurance. Section 280A(a) provides that, generally, taxpayers
may not deduct expenses (that are otherwise allowable) with
respect to the use of a dwelling unit that also serves as the
taxpayer's residence during the taxable year. There are several
exceptions to this rule. The limitations imposed by section 280A
do not apply to expenses attributable to any portion of a
taxpayer's dwelling unit used both exclusively and on a regular
basis as the principal place of petitioner's trade or business.
Sec. 280A(c)(1)(A). In the present instance, respondent argues
that petitioner has failed to show that the business use of his
residence was regular and exclusive.
In order for a taxpayer to establish use on a "regular"
basis, the business use must be more than occasional or
incidental. Jackson v. Commissioner, 76 T.C. 696, 700 (1981). A
taxpayer "exclusively" uses a portion of his dwelling in a trade
or business if the portion in question is not used for other than
business purposes. Sec. 1.280A-2(g)(1), Proposed Income Tax
Regs., 45 Fed. Reg. 52404 (Aug. 7, 1980); Hefti v. Commissioner,
T.C. Memo. 1993-128. Petitioner has not offered sufficient
evidence regarding the amount of time and nature of the work
conducted at his home to establish regular use. Browning v.
Commissioner, T.C. Memo. 1988-293, affd. 890 F.2d 1084 (9th Cir.
1989). Furthermore, petitioner has failed to prove that any
portion of his home was used exclusively for his writing
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