Peter C. Lafavor and Suzanne Lafavor - Page 2

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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