- 8 - taxpayer in a manner that is arbitrary and capricious. In Hamacher v. Commissioner, supra at 354, the Court recited the background for the enactment of section 280A's restriction upon deduction of home office expenses and pointed out that one of the reasons for the enactment of section 280A was a response by Congress to numerous cases, particularly those decided by this Court, which used a liberal standard to allow deduction of home office expenses that were "appropriate and helpful" to the taxpayer's business under the circumstances. Congress was concerned that, under such a standard, personal, living, and family expenses attributable to the home that are not otherwise deductible were being allowed as deductions. The purpose of section 280A was to restrict what Congress considered too liberal a standard in this area of tax law. The restrictive provisions of section 280A, therefore, apply to all taxpayers. The Court, therefore, rejects petitioners' contention that section 280A(c)(1) violates the Due Process Clause of the Fifth Amendment. Respondent determined that petitioners were liable for penalties under section 6662(a) for negligence or disregard of rules or regulations under section 6662(b)(1). Section 6662(a) provides that, if it is applicable to any portion of an underpayment in taxes, there shall be added to the tax an amount equal to 20 percent of the portion of thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011