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taxpayer's home. As an exception, this restriction does not
apply to any item that is allocable to a portion of the home that
is exclusively used on a regular basis as the principal place of
business for the taxpayer's trade or business. Sec. 280A(c).
Section 280A(c) requires that the taxpayer use the portion of the
home solely for the purpose of carrying on a trade or business
and that there be no personal use of that part of the home. See
Cadwallader v. Commissioner, 919 F.2d 1273, 1275 (7th Cir. 1990),
affg. T.C. Memo. 1989-356; Sam Goldberger, Inc. v. Commissioner,
88 T.C. 1532, 1556-1557 (1987). The legislative history of
section 280A provides:
Exclusive use of a portion of a taxpayer's dwelling unit
means that the taxpayer must use a specific part of a
dwelling unit solely for the purpose of carrying on his
trade or business. The use of a portion of a dwelling unit
for both personal purposes and for the carrying on of a
trade or business does not meet the exclusive use test.
Thus, for example, a taxpayer who uses a den in his dwelling
unit to write legal briefs, prepare tax returns, or engage
in similar activities as well as for personal purposes, will
be denied a deduction for the expenses paid or incurred in
connection with the use of the residence which are allocable
to these activities.
Sam Goldberger, Inc. v. Commissioner, supra (quoting S. Rept. 94-
938 (1976), 1976-3 C.B. (Vol. 3) 49, 186; H. Rept. 94-658 (1975),
1976-3 C.B. (Vol. 2) 695, 853).
The general rule of section 280A(a) does not apply to any
item that is allocable to space that is used on a regular basis
for storage of the taxpayer's inventory held for use in the
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