Clifford F. Asher - Page 6

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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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