2
After concessions,2 the issues for decision are whether
petitioners are entitled to deductions for various amounts
claimed as Schedule C expenses and whether petitioners are
entitled to a dependency exemption deduction with respect to
their married son.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein. Petitioners resided in Oak Park, Illinois,
at the time their petition was filed.
During the taxable year in issue, Paul M. Sengpiehl
(petitioner) was a self-employed attorney. Petitioner conducted
his legal practice out of petitioners' home in Oak Park,
Illinois. Petitioner did not maintain another office during the
year in issue.
Petitioners' residence has three stories, including an
unfinished basement. The basement measures 759 square feet. In
1991, the basement contained the heater and washing machine. It
contained no living area. Petitioner used 272 square feet of the
basement to store materials used in his law practice.
2 Petitioners concede they are not entitled to deductions for
car and truck expense in the amount of $930, depreciation expense
in the amount of $1,168, and insurance expense in the amount of
$1,667. Respondent concedes that petitioners are entitled to a
deduction for office expense in the amount of $6,030, and
petitioners concede that they are not entitled to a deduction for
the remaining amount of office expense claimed in the amount of
$1,092. Respondent further concedes that petitioners are
entitled to a Schedule C deduction for other expenses in the
amount of $1,889.35.
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