Les B. Martin and Millie A. Martin - Page 17

               Respondent also argues that many of the expenses petitioners           
          are claiming for business appear to be household expenses, and that         
          they did not prove that these expenses are ordinary and necessary           
          business expenses.  For example, Mr. Martin claimed expenses for            
          plumbing, installing a fireplace door, snow removal, pest spraying,         
          and repair and maintenance of a deck.  Mrs. Martin claimed expenses         
          for sewage and garbage collection and stress training.  Respondent          
          also argues that most of the furniture Mr. Martin purchased for his         
          home office was more of a personal nature than for business.                
          Respondent notes that  Mr. Martin had no income from his Schedule           
          C activity during 1989 and 1990.                                            
               Section 262 denies a deduction for any personal, living, or            
          family expenses.  With respect to deductions under section 162, the         
          taxpayer bears the burden of proving that an expense was incurred           
          for business, rather than personal reasons.   Walliser  v.                  
          Commissioner, 72 T.C. 433, 437 (1979).  Specifically, the taxpayer          
          must show that the expense was incurred primarily to benefit                
          his/her business, and there must be a proximate, rather than a              
          remote or incidental, relationship between the claimed expenses and         
          the taxpayer's business.  Id.  In the instant case, petitioners             
          failed to substantiate that some of the claimed expenses were               
          incurred primarily to benefit their Schedule C businesses.                  
          Further, we do not find that petitioners used (as required by sec.          
          280A(c)) that portion of their residence claimed as a home office           
          either (a) as the principal place of business for their claimed             

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