Kenneth Miles and Michon Snow Tesar - Page 13

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          ordinary or necessary in his trade or business as a teacher of              
          mathematics.  The school only required that sponsors of                     
          extracurricular activities supervise the students.  Furthermore,            
          while faculty sponsors commonly bought snacks for their students,           
          there is no evidence that they ordinarily purchased supplies with           
          personal funds for the activities.  Petitioner collected comic              
          books as a hobby, and when he left his job at the school he                 
          retrieved for his own collection many of the comic books that he            
          had ordered for the club.  Petitioners have not established that            
          the costs of the comic books are deductible business expenses.              
          See Wheatland v. Commissioner, T.C. Memo. 1964-95; Mann v.                  
          Commissioner, T.C. Memo. 1993-201.                                          
               Petitioners argue that they are entitled to deduct expense             
          incurred with respect to Mrs. Tesar's home office.  Respondent              
          counters that Mrs. Tesar's home office was not her principal                
          place of business, and, therefore, petitioners may not deduct the           
          expenses incurred therewith.                                                
               Section 280A generally prohibits deduction of otherwise                
          allowable expenses with respect to the use of an individual                 
          taxpayer's home.  As an exception, this restriction does not                
          apply to:                                                                   
               any item to the extent such item is allocable to a                     
               portion of the dwelling unit which is exclusively used                 
               on a regular basis--                                                   
                         (A) [as] the principal place of business for                 
                    any trade or business of the taxpayer,                            




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