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The principal place of petitioner's fishing business appears
to have been in Alaska and Washington State. No revenue
producing activities were performed in petitioners' home.
Petitioners' basement room, the shed, and garage fail to qualify
as the principal place of petitioner's fishing business.
Arguably, petitioners' shed might qualify under the
separate-structure exception of section 280A(c)(1)(C).
Petitioner however, has not substantiated the portion of the
claimed home office deductions that might be allocable to the
shed.
For the reasons stated, we conclude that petitioners are not
entitled to the claimed home office deductions under section 280A
relating to petitioner's fishing business.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011