Peter C. Lafavor and Suzanne Lafavor - Page 3

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               During 1991 and 1992, petitioner used one room in the                  
          basement of petitioners' home to make phone calls to plan his               
          fishing trips and to negotiate fishing charters of the Bounty.              
          Petitioner used a shed on petitioners' property for storage of              
          petitioner's fishing gear and of records relating to the Bounty.            
          Petitioner also used a garage on petitioners' property to store a           
          family car that occasionally was used in petitioner's fishing               
               Petitioner did not maintain adequate records documenting his           
          activities in his fishing business.                                         
               On petitioners' 1991 and 1992 joint Federal income tax                 
          returns, petitioners claimed home office deductions of $2,226 and           
          $2,506, respectively, relating to the use of petitioners'                   
          basement room, shed, and garage in petitioner's fishing business.           
          In calculating the amount of claimed home office deductions,                
          petitioners treated 100 percent of the basement room and shed and           
          30 percent of the garage as used for business purposes.                     
               On audit for 1991 and 1992, respondent disallowed in full              
          petitioners' claimed home office deductions.                                

               Section 162 generally allows a deduction for ordinary and              
          necessary expenses incurred in carrying on a trade or business.             
          Under section 280A(c)(1)(A), ordinary business expenses relating            

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