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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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