Paul M. and June S. Sengpiehl - Page 10

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          Commissioner, T.C. Memo. 1988-22, affd. without published opinion           
          894 F.2d 1340 (8th Cir. 1989).                                              
               Petitioner testified that he used the living room as an                
          informal meeting area and as a conference room in his legal                 
          practice.  Petitioner testified that he met with at least 54                
          clients in this room during 1991.  Petitioner testified that he             
          and Mrs. Sengpiehl usually did not entertain at home and that               
          their children never had guests at the house.  He further                   
          testified that he was the only member of the family who played              
          the piano and that he did not do so during the year in issue.               
          Two of petitioners' clients testified that when they met with               
          petitioner, they had free access to the entire first floor, and             
          testified to meeting with petitioner in the living room.                    
               We found the witnesses' testimony credible concerning the              
          use of the living room for business purposes.  We have no basis             
          for doubting petitioner's testimony that the living room was not            
          used for personal reasons when petitioner admitted to making                
          personal use of other rooms.  Therefore, we find that petitioners           
          have satisfied the requirements of section 280A(c)(1) with regard           
          to the living room.                                                         
               Petitioners argue that one-half of the kitchen space is part           
          of petitioner's home office.  Respondent contends petitioners               
          have failed to prove that any part of the kitchen was used                  
          exclusively for business purposes.  We agree with respondent.               






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