Kenneth Miles and Michon Snow Tesar - Page 15

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          persuade us that her principal place of business was in her home            
          where none of the physical therapy was performed.  Petitioners              
          have failed to prove that Mrs. Tesar's home office was her                  
          principal place of business.                                                
               Petitioners assert that Mrs. Tesar met with some patients at           
          her home office.  However, there is no evidence in the record to            
          establish that these meetings occurred or the frequency or                  
          regularity of the alleged meetings.  Thus, petitioners have not             
          established that Mrs. Tesar's home office was used by her                   
          patients in meeting with her in the normal course of her                    
          business.                                                                   
               Petitioners have not established that any of the exceptions            
          in section 280A apply.  Accordingly, petitioners are not entitled           
          to a deduction in 1991 or 1992 related to Mrs. Tesar's use of               
          their home for business purposes.  Respondent is sustained on               
          this issue.                                                                 
               Petitioners argue that they are entitled to deduct                     
          automobile expense incurred by Mrs. Tesar in carrying on her                
          business during 1991 and 1992.  Respondent contends that                    
          petitioners have not substantiated any automobile expense                   
          incurred by Mrs. Tesar.  Further, respondent argues that even if            
          petitioners substantiate the expense, petitioners would not be              
          entitled to a deduction for the costs associated with                       
          Mrs. Tesar's trips between their home and the place where she               





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