- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions by the parties, the sole issue for decision is whether petitioner is entitled to a business deduction for the cost of certain meals in the amount of $450 for the taxable year 1994. We hold that she is not. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts are incorporated into these findings by this reference. When the petition in this case was filed, petitioner resided in Sunnyvale, California. During 1994, petitioner was self-employed as a licensed acupuncturist. She maintained a business address in San Jose, California, for all of 1994, and in Sunnyvale, California, for part of the year. Petitioner shared office space at the San Jose address with a chiropractor, Dr. Catherine Zimmerman, who used the office Mondays, Wednesdays, and Fridays. Petitioner used the office Tuesdays and Thursdays. Petitioner paid Dr. Zimmerman rent, and they shared office expenses. They also treated some patients inPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011