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Moreover, it is irrelevant whether petitioner claims the
deduction under section 212 if it is not allowable under section
162. It is well established that a taxpayer is not entitled to a
home office expense deduction for a section 212 activity that
does not rise to the level of a trade or business within the
meaning of section 162. Moller v. United States, 721 F.2d 810,
813 (Fed. Cir. 1983); Curphey v. Commissioner, 73 T.C. 766, 770
(1980).
The second item, petitioner’s expenditure of $35 for
maintenance of his Keogh plan, would not be an expense of
carrying on petitioner’s paralegal activity but would be
deductible under section 212 as a Schedule A itemized deduction.
See Rev. Rul. 84-146, 1984-2 C.B. 61.
In his reply brief, petitioner alleges that if the Court
sustains the disallowance of some of the claimed expenses, he has
additional unclaimed expenses as an offset. Attached to the
reply brief were copies of numerous documents which were not
offered at trial. Petitioner contends that he is entitled to
claim the additional expenses under Rule 155. Petitioner is
wrong. The time for presenting evidence is at trial. Generally,
the Court does not try a case piecemeal. New issues may not be
raised after the trial has been concluded and the record closed.
Moreover, evidence may not be submitted or attached to posttrial
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