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all Rule references are to the Tax Court Rules of Practice and
Procedure. References to petitioner in the singular are to Peter
C. LaFavor.
After settlement, the issue remaining for decision is
whether certain expenses qualify as deductible home office
expenses under section 280A.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
During 1991 and 1992, petitioner traveled to Alaska and
Washington State and worked there as a self-employed commercial
fisherman. When petitioner was not fishing in Alaska or
Washington State, he resided with his family in Afton, Minnesota,
where his family resided throughout the year. Petitioner also
worked in Minnesota at miscellaneous jobs such as removing snow
and delivering packages.
During 1991 and 1992, petitioner owned shares of stock in an
S corporation known as Triple L-F/V Bounty, Inc. (Triple).
Petitioner, his father, and his brother each owned one-third of
the shares of stock in Triple. The only asset of Triple was a
fishing boat referred to as the Bounty that petitioner
occasionally used in his fishing business in Alaska and
Washington State.
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Last modified: May 25, 2011