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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 in
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