- 22 - business establishment if the requirements of section 280A(c)(1) are met. Section 280A(c)(1), in turn, allows deductions allocable to the portion of a dwelling unit that is exclusively used on a regular basis as the principal place of business for any trade or business of the taxpayer. As noted above, respondent at trial conceded petitioners' entitlement to a home office deduction for the portion of their dwelling used in connection with their trade or business and rental properties. With this concession, it follows that petitioners' computer is excepted from the definition of "listed property" under section 280F(d)(4)(B); thus, the strict substantiation requirements of section 274(d) are not applicable. Petitioners substantiated their purchase of the equipment, and the Court is satisfied that the computer was used for business and investment purposes. Petitioners, therefore, are entitled to depreciation deductions on their computer for the 2 years at issue. The trade or business activity of petitioners previously referred to was conducted by Mr. Zeidler under the trade name of GLZ Financial Services. He provided consulting and estate planning services and was also licensed to sell insurance. Petitioners reported their income and expenses from this activity on Schedule C, Profit or Loss From Business, of their returns. In the notices of deficiency, respondent disallowed several of the expenses claimed by petitioners for each of the years inPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011