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income earned by the activity. Petitioners contend that,
pursuant to Internal Revenue Service Publication 587, Business
Use of Your Home, only the deductibility of the portion of the
home used as a home office is limited by section 280A(c)(5), and
there is no limitation on the deduction for inventory storage.
Accordingly, petitioners claim they are entitled to deduct their
inventory storage costs regardless of the amount of income
generated by the activity during the taxable year.
Section 280A(c)(5) specifically limits the deduction for
both an office in the home and for inventory storage to the
"gross income derived from such use for the taxable year". Since
petitioners used the home office and inventory storage for the
same business activity, petitioners' total deduction for both of
these spaces in their residence is limited to $435.53, the income
earned from the activity during 1992.
With respect to petitioners' reliance on Publication 587,
while the publication is not completely clear with respect to the
applicability of the section 280A(c)(5) income limitations to
deductions for inventory storage, regardless of the
interpretations or conclusions reached by petitioners from this
publication, it is well settled that authoritative tax law is
contained in statutes, regulations, and judicial decisions and
not in informal publications. Zimmerman v. Commissioner, 71 T.C.
367, 371 (1978), affd. without published opinion 614 F.2d 1294
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