Peter C. Lafavor and Suzanne Lafavor - Page 4

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          to use of any portion of a taxpayer's home are not allowable                
          unless the taxpayer establishes that the portion of the                     
          taxpayer's home to which the expenses relate was used exclusively           
          and on a regular basis as the principal place of the taxpayer's             
          trade or business.  Hamacher v. Commissioner, 94 T.C. 348, 353              
          (1990).  Occasional use of a portion of a taxpayer's home for               
          business purposes will not satisfy the requirements of section              
          280A(c).  Anderson v. Commissioner, T.C. Memo. 1982-576.                    
                With regard to the principal-place-of-business                        
          requirement, the Supreme Court in Commissioner v. Soliman, 506              
          U.S. 168, 174 (1993), explained that "principal" meant the most             
          important or significant place for business.  Whether the                   
          principal-place-of-business requirement is satisfied turns on the           
          relative importance of the business activities performed in the             
          home and the time spent in the home conducting these activities.            
          Id. at 175.                                                                 
               Petitioner argues that his various fishing activities in               
          petitioners' basement room, shed, and garage qualify under the              
          requirements of section 280A.  We disagree.                                 
               The evidence does not establish that petitioner's use of the           
          basement room, the shed, and the garage separately or together              
          qualifies as the principal place of petitioner's fishing                    

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