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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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