10
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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