Michel L. Dixon - Page 5




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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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