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with the State of California, and used the corporate business
address on his Federal income tax returns.
During 1991, the corporation needed more office space3 and
constructed a loft area in the office building. The cost of
constructing the loft was $75,096. The loft area consists of
approximately 1,200 square feet and includes offices, a storage
area, a lounge area with a kitchen (285 square feet), and a
bathroom with a shower (45 square feet). Another bathroom is
located in the back of the office building. The new bathroom was
constructed so that petitioner and clients would not have to walk
through the manufacturing area to the other bathroom. Petitioner
uses the lounge area to meet with clients. The kitchen has a
sink and microwave but is not equipped with a stove or pots and
pans.
After work Donald Asher likes to work out before going home.
He requested the shower be installed so that he could shower
before going home after working out. Donald Asher lived in the
loft for a few weeks following a domestic dispute with his wife
until he could find an apartment. He slept on a mattress on the
floor in the storage room. Petitioner does not use the shower
and has never lived in the loft.
3Donald Asher had become the production manager and took
over petitioner's office space.
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Last modified: May 25, 2011