- 9 -
frame. We conclude that both of the $1,500 checks reflect
transfers, but respondent has treated only one as a transfer. We
therefore agree with petitioner that 1990 gross income as
determined by respondent, and as reduced by respondent's
concessions noted in our Findings of Fact, should be further
reduced by an additional $1,500.
Issue 2. Miscellaneous Deductions
FINDINGS OF FACT AND OPINION
In 1988 petitioner opened an office located at 100 Pine
Street in downtown San Francisco and continued to rent this
office space during the three years in issue. Respondent allowed
the amount of the rent as a deduction in each year. Petitioner
resided in a studio apartment at 770 California Street, San
Francisco, during these years. His apartment was six blocks from
his office.
a. Office Expense
Although petitioner did not seek to deduct any part of his
apartment rent as a business deduction, he claimed the use of his
apartment as an office and sought to deduct as office expense the
cost of many furnishings for his apartment. The amount claimed
on each return as office expenses, the amounts allowed by
respondent, and the adjustments to petitioner's claimed Schedule
C office expenses are as follows:
1988 1989 1990
Per return $1,881 $9,078 $4,828
Page: 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