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relating to the business of Mrs. Martin. Thus, the total expenses
petitioners claimed for 1989 on their amended return for both
businesses was $21,774. Respondent contends that petitioners
should be allowed no Schedule C expenses for the year 1989 other
than those expenses already allowed by respondent in the statutory
notice.
Petitioners originally claimed a $12,489 Schedule C business
loss for 1990 that resulted from their claiming $12,489 in business
expenses and no gross receipts. The statutory notice disallowed
all of the claimed expenses. On their amended 1990 return,
petitioners claimed $8,349 in expenses relating to the business of
Mr. Martin, and $4,948 in expenses relating to the business of Mrs.
Martin. Thus, the total expenses petitioners claimed for 1990 on
their amended return for both businesses was $13,297. Respondent
contends that petitioners are entitled to no Schedule C expenses
for 1990.
Petitioner and Mrs. Martin each claimed a home office
deduction. Respondent contends that with respect to 1989, Mr.
Martin used his office until September 20, 1989, both for his
consulting business and as an employee, thus violating the
exclusive-use requirement of section 280A(c)(1) because his use of
a home office as an employee was not for the convenience of his
employer.4
4 Mr. Martin used his claimed home office in connection
with his work as president of Aero-Motive until Sept. 20, 1989.
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