- 15 - 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 shePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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