Jeffrey C. and Kelly O. Stone - Page 7

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          predominant motive for the expense was related to the business,             
          and petitioners have failed to establish such a motive.  Finally,           
          the costs of Mr. Stone's lunches are nondeductible.  Murphey v.             
          Commissioner, T.C. Memo. 1975-317.                                          
          2.  Travel Expenses                                                         
               Petitioners provided receipts totaling $739 that they                  
          maintain represent business traveling expenses.  According to Mr.           
          Stone these expenses were incurred when they met with friends who           
          were or had been their customers, when they went to visit Mrs.              
          Stone's parents, and when they attended a baseball tournament in            
          Idaho Falls.  It is apparent that the primary or dominant purpose           
          of these trips was personal, and whatever attention to business             
          matters there may have been was relatively insignificant.  These            
          expenses are not deductible.  Holmes v. Commissioner, T.C. Memo.            
          1983-442.                                                                   
          3.  Home and Repair Expenses                                                
               Petitioners deducted various expenses with regard to their             
          personal residence including various repairs, utility services,             
          and supply expenses.  The rationale for deducting these expenses            
          is that a telephone used by Mrs. Stone in the appliance repair              
          business was located on the ground floor of their residence,                
          which constituted 25 percent of the space of the home.                      
               Section 280A(a) provides generally that "no deduction * * *            
          shall be allowed with respect to the use of a dwelling unit which           
          is used by the taxpayer during the taxable year as a residence."            




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