Reza and Connie M. Rezazadeh - Page 22

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          petitioners' personal residence.  On their 1992 Federal income              
          tax return, petitioners filed a Schedule C in which the income              
          and expenses of this activity were reported as a trade or                   
          business.  Among the expenses claimed were expenses related to an           
          office in the home in which petitioners claimed one-eighth of the           
          expenses of their home as being attributable to this business               
          activity.  The one eighth portion of the home office expenses               
          claimed were the following:                                                 

                              $218.89  Utilities                                      
                              222.54  Property taxes                                  
                              360.00  House depreciation                              
                              $801.43  Total                                          

          Petitioners claimed only $435.53 of this amount as a deduction,             
          pursuant to section 280A(c), which limits the home office                   
          deduction to the amount of income from the activity that, in                
          petitioners' case, was $435.53 for 1992.  However, petitioners              
          additionally claimed a deduction of $801.43 that is described on            
          the Schedule C as "Storage of Inventory Cost, one-eighth of the             
          total space, calculated as above."  In the notice of deficiency,            
          respondent did not question petitioners' entitlement to a                   
          deduction of expenses for an office in the home but disallowed              
          the $801.43 claimed for "Storage of Inventory Cost" because the             
          claimed storage expenses related to the same business activity,             
          the writing and publishing of books, and was also subject to                






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