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income tax return for 1984 when he was living at a different
address and working for a different employer. Petitioner argues
that he is entitled to a home office deduction for 1993 because:
(1) He wrote letters to various school boards on his personal
computer, which was set up on the table in the dining area of his
apartment; and (2) messages in response to his letters were left
on his home answering machine.
In general, a taxpayer is not entitled to deduct any
expenses related to the use of a dwelling unit used by the
taxpayer as a residence during the taxable year. See sec. 280A.
Expenses attributable to a home office are excepted from this
general rule, however, if the expenses are allocable to a portion
of the dwelling unit which is exclusively used on a regular basis
as the principal place of business for the taxpayer's trade or
business. See sec. 280A(c)(1).
During 1993, no portion of petitioner's apartment was
exclusively used on a regular basis as petitioner's principal
place of business. The fact that petitioner might have been
allowed a home office deduction for a prior year under different
circumstances is of no consequence. Petitioner is not entitled
to a home office deduction for 1993, and respondent's
determination in this regard is sustained.
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Last modified: May 25, 2011